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' 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 was tried on charges alleging that he distributed cocaine and trafficked in cocaine, in violation of Mass. Gen. Laws ch. 94C, §§ 32A and 32E(b)(1). At his trial, the prosecution introduced as evidence certificates of state laboratory analysts indicating that material seized by police and connected to Diaz was cocaine of a certain quantity. As required by Massachusetts law, the certificates were sworn to before a notary public and were submitted as prima facie evidence of what they asserted. Diaz objected to admission of the certificates, claiming that their admission violated his right under the Sixth Amendment to the U.S. Constitution to confront the analysts who signed the certificates. The trial court overruled the objection, the certificates were admitted, and Diaz was convicted. The Massachusetts Appeals Court affirmed, rejecting Diaz's claim that the certificates' admission violated his Sixth Amendment rights.
Did the Commonwealth of Massachusetts violate Diaz's constitutional rights by admitting the certificates into evidence?
The U.S. Supreme Court held that admission of the certificates violated Diaz'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. Although Diaz could have subpoenaed the analysts, that right was not a substitute for his right to confront them. The U.S. Supreme Court reversed the judgment of the Appeals Court of Massachusetts and remanded the case for further proceedings.
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