As regular readers know, the U.S. Supreme Court decided Smith v. Arizona, 602 U.S. 779 (2024), this past June. The decision undercut the reasoning used by North Carolina courts to justify the practice of permitting substitute analysts to offer an independent opinion about the forensic report of another, nontestifying analyst (as discussed here and here). Until this week, no North Carolina court had applied Smith. The wait is now over. In State v. Clark, NCCOA-1133, ___ N.C. App. ___ (Dec. 3, 2024), the Court of Appeals delved into the impact of Smith on North Carolina law, ultimately granting the defendant a new trial for a Confrontation Clause violation. This post discusses the Clark decision and its implications for the future of substitute analysts in the state.