In the case of Williams v. Illinois, the U.S. Supreme Court ruled in 2011 that a forensic report could be admitted as evidence without having the author testify at trial. The defendant, Sandy Williams, was convicted for rape and murder based on DNA evidence linking him to the crime scene. However, he argued that his Sixth Amendment right to confront witnesses against him was violated because he did not have an opportunity to cross-examine technicians from Cellmark Laboratories who prepared a DNA profile used by state experts during their testimony. In a 5-4 decision led by Justice Samuel Alito Jr., it was held that this did not violate William's rights under Confrontation Clause since expert witness testified about her independent review of lab results rather than simply relaying information from non-testifying analysts' reports.

In the dissenting opinion for Williams v. Illinois, Justice Kagan, joined by Justices Scalia, Ginsburg and Sotomayor argued that the majority's decision violated the Confrontation Clause of the Sixth Amendment which gives a defendant in a criminal case the right to confront witnesses against them. The dissenters believed that allowing an expert witness to testify about DNA testing results conducted by non-testifying analysts was essentially allowing hearsay evidence into court proceedings. They contended that this undermined defendants' rights as it denied them their constitutional right to cross-examine those who had produced evidence against them. In essence, they disagreed with how far removed from direct confrontation one could be before violating these rights and felt this ruling stretched it too far.