LEGAL GUIDE
Written by attorney Elisa M Reiter | Jul 25, 2018

Melendez Diaz v. Massachusetts -- CAN BAD LAB RESULTS ALWAYS BE USED AGAINST YOU?

Held: The admission of the certificates violated petitioner’s SixthAmendment right to confront the witnesses against him. Pp. 3–23. (a) Under Crawford, a witness’s testimony against a defendant isinadmissible unless the witness appears at trial or, if the witness isunavailable, the defendant had a prior opportunity for cross-examination. 541 U. S., at 54. The certificates here are affidavits, which fall within the “core class of testimonial statements” covered by the Confrontation Clause, id., at 51. They asserted that the sub-stance found in petitioner’s possession was, as the prosecutionclaimed, cocaine of a certain weight—the precise testimony the ana-lysts would be expected to provide if called at trial. Not only were the certificates made, as Crawford required for testimonial statements,“under circumstances which would lead an objective witness rea-sonably to believe that the statement would be available for use at alater trial,” id., at 52, but under the relevant Massachusetts law their sole purpose was to provide prima facie evidence of the substance’s composition, quality, and net weight. Petitioner was entitled to “be confronted with” the persons giving this testimony at trial. Id., at 54.

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