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Paredes v. State

Court of Criminal Appeals of Texas
462 S.W.3d 510 (2015)


Facts

The State of Texas (plaintiff) charged Paredes (defendant) with murder. In the process of its investigation, the police recovered a shirt allegedly worn by Paredes on the night of the crime. Investigators sent the shirt to a private forensic laboratory for DNA testing. At trial, the prosecution called Robin Freeman as an expert witness. Freeman was the director of the laboratory and had supervised the testing of the blood on the shirt. Freeman did not conduct each portion of the DNA testing but oversaw the entire process and made a final determination on whether there was a match with a victim based on computer-generated data. None of the lab workers that had actually conducted the DNA testing testified at Paredes’s trial. Freeman testified that the DNA tests revealed that blood on the shirt matched the blood of one of the victims. The prosecution did not introduce any of the reports that other lab analysts created. Paredes objected to Freeman’s testimony on the ground that the Confrontation Clause required that Paredes be able to cross-examine the lab workers who had actually conducted the DNA testing. The trial court overruled Paredes’s objection. A jury convicted Paredes, and the court of appeals affirmed. Paredes appealed.

Rule of Law

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Issue

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Holding and Reasoning (Newell, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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