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Name: Melendez-Diaz v. Massachusetts
Case #: 07-591
Court: US Supreme Court
District USSup
Opinion Date: 06/25/2009
Subsequent History: 129 S.Ct. 2527; 174 L.Ed.2d 314
Summary

Notarized certificates prepared by laboratory analysts identifying the type and amount of seized contraband are testimonial statements and, as such, are only admissible subject to the petitioner’s right of cross-examination under the Sixth Amendment of the Constitution. Petitioner was arrested and prosecuted for narcotic trafficking. At trial, over petitioner’s objection, the court permitted introduction of notarized certificates prepared by laboratory analysts that stated that the substance seized and connected to petitioner was cocaine of a specified weight. Granting certiorari, the Supreme Court ruled that admission of the certificates violated petitioner’s Sixth Amendment right to confront witnesses against him. The certificates are exactly the type of evidence contemplated by the court in Crawford v. Washington (2004) 541 U.S. 36, discussing the right of confrontation. They were made under circumstances that would lead an objective witness to reasonably believe they would later be used for trial. In fact, under Massachusetts law their sole purpose was to provide prima facie evidence of weight, composition, and quality of the substance. The Court rejected respondent’s arguments, finding the following: the analysts are accusatory witnesses; witnesses such as analysts, who testify regarding facts other than those observed at the crime scene are not necessarily exempt from cross-examination; a witness who volunteers his testimony, as does the lab analyst, still remains a witness for Sixth Amendment purposes; the affidavits did not qualify as business records; the power of petitioner to subpoena the analyst is of no consequence; and simply because the prosecution’s task may be more burdensome as a result of a requirement that he present the analyst for trial is not relevant and has not even been proven to be the case.