The issue presented in Melendez-Diaz v. Massachusetts (No. 07–591) was:
Whether a state forensic analyst’s laboratory report prepared for use in a criminal prosecution is 'testimonial' evidence subject to the demands of the Confrontation Clause as set forth in Crawford v. Washington, 541 U.S. 36 (2004).
Summary For: Luis E. Melendez-Diaz v. Massachusetts
- Summary Facts: Petitioner Melendez-Diaz was charged with cocaine trafficking after officers observed what appeared to be a drug transaction. At trial, the state prosecutor introduced some bags of cocaine seized in the case. The prosecutor also introduced a forensic lab reports prepared by a lab technician who identified the powder in the bags as cocaine. The prosecutor did not call a forensic examiner. Instead, the prosecutor relied on a state procedural law which permitted the admission of extra-judicial notarized drug analysis certificates declaring under oath that the substance in the bags contained cocaine. See Commonwealth v. Luis E. Melendez-Diaz, 69 Mass. App. Ct. 1114, 870 N.E.2d 676 (Mass. App. 2007) (No. 05-P-1213) (Memorandum and Order Pursuant to Rule 1:28, No. 05-P-1213 (Mass App. July 31, 2007)); see also State Exhibit 11 (example of one of the notarized drug analysis certificates in the case).
- Claim On Appeal: On appeal following his state court conviction, the petitioner contended that his Confrontation Clause rights were violated by the introduction of the crime lab reports as he was not allowed an opportunity to cross-examine the expert who prepared the drug analysis certificates.
- Lower Court Action: The state conviction was affirmed on appeal. See Commonwealth v. Luis E. Melendez-Diaz, 69 Mass. App. Ct. 1114, 870 N.E.2d 676 (Mass. App. 2007) (No. 05-P-1213).
- Certiorari Review: On March 17, 2008, the Supreme Court granted certiorari review of the state court judgment.
- Supreme Court Docket: Docket.
- Oral Argument and Transcript: On November 10, 2008, the Supreme Court heard oral argument on the case. See Luis E. Melendez-Diaz v. Massachusetts (No. 07-591) Oral Argument Transcript.
- Decision: The Supreme Court reversed and remanded the judgment of the Massachusetts Appeals Court on June 25, 2009. The Supreme Court held in Melendez-Diaz v. Massachusetts that certificates of forensic analysis are "testimonial" and "the Sixth Amendment does not permit the prosecution to prove its case via ex parte out-of-court affidavits."
- Blog Posts: From the Federal Evidence Blog discussing the Melendez-Diaz case are available here.
- Recent Supreme Court Case In Briscoe, et al., v. Virginia: On June 29, 2009, four days after the opinion in Melendez-Diaz v. Massachusetts, 557 U.S. __, 129 S. Ct. 2527 (2009), the Supreme Court granted certiorari in Briscoe, et al., v. Virginia (07-11191). The question presented in the case concerned whether the state can "avoid" its obligation to make a lab analyst who prepared a testimonial report available for defense cross-examination "by providing ... the accused ... a right to call the analyst as his own witness” at trial. On January 25, 2010, the Supreme Court vacated and remanded the case “for further proceedings not inconsistent with the opinion in Melendez-Diaz v. Massachusetts, 557 U. S. ___ (2009).” Briscoe v. Virginia, 559 U. S. __ (2010) (per curiam) (07-11191) . For more on the Briscoe v. Virginia case, see Supreme Court Watch: Certiorari Granted In Briscoe v. Virginia: Confrontation Clause Case Set For 2010 Supreme Court Term ; Supreme Court Watch: Summary Of Briscoe Oral Argument ; Supreme Court Watch: Impact From Briscoe v. Virginia Remand.