Law School Case Brief
Melendez-Diaz v. Massachusetts - 557 U.S. 305, 129 S. Ct. 2527 (2009)
The Sixth Amendment to the United States Constitution, made applicable to the States via the Fourteenth Amendment, provides that in all criminal prosecutions, the accused shall enjoy the right to be confronted with the witnesses against him. In Crawford v. Washington, the United States Supreme Court held that the Sixth Amendment guarantees a defendant's right to confront those who bear testimony against him. A witness's testimony against a defendant is thus inadmissible unless the witness appears at trial or, if the witness is unavailable, the defendant had a prior opportunity for cross-examination.
Luis Melendez-Diaz, the petitioner, was tried on charges alleging that he distributed cocaine and trafficked in cocaine, in violation of Massachusetts law. The prosecution offered certificates signed by state laboratory analysts, which stated that evidence that was connected to petitioner was cocaine. The petitioner objected to the admission of the certificates, asserting that jurisprudence of the Confrontation Clause required the analysts to testify in person. The objection was overruled, and the certificates were admitted pursuant to state law as “prima facie evidence of the composition, quality, and the net weight of the narcotic analyzed.” The jury found Melendez-Diaz guilty. He appealed, contending, among other things, that the admission of the certificates violated his Sixth Amendment right to be confronted with the witnesses against him.
Did the admission of the certificates as evidence violate the Confrontation Clause?
The U.S. Supreme Court held that admission of the certificates violated petitioner's Sixth Amendment right to confront the witnesses against him. The certificates were affidavits, which fell within the core class of testimonial statements covered by the Confrontation Clause, and they were made under circumstances which would have led an objective witness reasonably to believe that they were made for use in a criminal trial. The Court noted that although petitioner could have subpoenaed the analysts, that right was not a substitute for his right to confront them. The Sixth Amendment does not permit the prosecution to prove its case via ex parte out-of-court affidavits, and the admission of such evidence against Melendez-Diaz was error.
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