State of Tennessee v. Sabrina Renee Lewis

Summary

The Tennessee Supreme Court affirmed Sabrina Lewis's convictions for criminally negligent homicide and facilitation of attempted especially aggravated robbery and her effective twenty-one-year sentence, resolving three evidentiary challenges. It held that a party-opponent statement need not be against the declarant's interest to be admissible under Rule 803(1.2), that the dying declaration exception survives Crawford even when the declaration is testimonial, and that an expert's evaluation of DNA data produced by a non-testifying analyst does not violate the right of confrontation. The court also announced that a Roberts reliability analysis is unnecessary for nontestimonial hearsay under either the federal or the Tennessee constitution.