In People v. Rawlins and People v. Meekins, the New York Court of Appeals addressed, for the first time, the admissibility of scientific reports prepared by non-testifying forensic experts for use by the prosecution in a criminal trial under the Sixth Amendment's Confrontation Clause. Rawlins involved a fingerprint comparison report prepared by a police forensic expert, and Meekins involved a DNA profile prepared by a technician in a private laboratory. The constitutional issue in both cases was whether these reports were “testimonial” statements within the meaning of the Confrontation Clause, as interpreted by the Supreme Court in Crawford v. Washington, and should not have been admitted into evidence unless the defendants had an opportunity to cross-examine the experts who prepared the reports.
Bennett L. Gershman, Confronting Scientific Reports Under Crawford v. Washington, 29 Pace L. Rev. 479 (2009), http://digitalcommons.pace.edu/lawfaculty/573/.