## Facts

- Jovany Paredes participated in an armed robbery in which two victims were shot and killed.
- After the offense, Paredes gave a T-shirt allegedly worn during the crime to an associate to wash; the associate contacted police, and the shirt was seized.
- The shirt was submitted to a private DNA laboratory using an assembly-line batch process in which different analysts performed separate mechanical steps to generate raw DNA data.
- The laboratory director supervised the process, reviewed quality controls, and performed the final interpretation by comparing the DNA profile from the shirt stain to a known victim sample.
- At trial, the State presented the director’s testimony and did not introduce written reports or certifications from the non-testifying analysts who performed individual steps.
- Paredes objected that admitting the director’s testimony violated the Sixth Amendment Confrontation Clause because the analysts who performed the testing steps did not testify.
- The trial court overruled the objection; Paredes was convicted of capital murder and sentenced to life without parole; the intermediate court affirmed.

## Issues

1. Whether the Confrontation Clause is violated when a supervising DNA analyst testifies to a DNA match opinion based on computer-generated raw data from batch testing, even though other analysts performed various testing steps and did not testify.

## Decision

- The Texas Court of Criminal Appeals affirmed.
- The court held that admitting the supervising analyst’s in-court DNA-match opinion did not violate the Confrontation Clause.
- The court concluded the opinion was based on non-testimonial, computer-generated raw data and the analyst’s own interpretation, not on the admission of testimonial statements from non-testifying analysts.

## Legal Principles

- The Confrontation Clause bars admission of testimonial statements from absent witnesses unless the witness is unavailable and the defendant had a prior opportunity to cross-examine.
- Machine- or computer-generated raw data, without a person’s formalized assertion, is not a testimonial statement for Confrontation Clause purposes.
- A testifying expert may rely on data and work performed by others if the expert presents an independent judgment rather than transmitting another analyst’s testimonial conclusions.
- Confrontation concerns are heightened when the prosecution introduces formal lab reports or certifications that assert guilt-related facts through a non-testifying analyst; the absence of such admitted reports supports admission of a qualified testifying analyst’s independent opinion.

## Conclusion

The court upheld admission of a supervising laboratory director’s DNA-match testimony where the State offered no non-testifying analysts’ formal reports and the director independently interpreted non-testimonial, machine-generated DNA data generated through batch testing while being available for cross-examination.


Paredes v. State, 462 S.W.3d 510 (Tex. Crim. App. 2015)