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.
If It Looks LIke Cocaine, Must It Be Cocaine?A KMart employee was observed stepping out of the store on numerous occasions to meet a blue sedan. An informant at the store felt the activity was suspicious. Surveillance was set up, and the employee was stopped and searched after stepping out to said sedan. The search gleaned three plastic bags containing a white powdery substance. A subsequent search of the vehicle gleaned 19 small bags in the vehicle.
"Melendez-Diaz was charged with distributing cocaine and with trafficking in cocaine in an amount between 14 and 28 grams. Ch. 94C, **32A, 32E(b)(1). At trial, the prosecution placed into evidence the bags seized from Wright and from the police cruiser. It also submitted three *certificates of analysis* showing the results of the forensic analysis performed on the seized substances. The certificates reported the weight of the seized bags and stated that the bags *[h]a[ve] been examined with the following results: The substance was found to contain: Cocaine.* App. to Pet. for Cert. 24a, 26a, 28a. The certificates were sworn to before a notary public by analysts at the State Laboratory Institute of the Massachusetts Department of Public Health, as required under Massachusetts law. Mass. Gen. Laws, ch. 111, *13.
Petitioner objected to the admission of the certificates, asserting that our Confrontation Clause decision in Craw-ford v. Washington, 541 U. S. 36 (2004), 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.* Mass. Gen. Laws, ch. 111, *13."
Right to Confront WitnessesThe Sixth Amendment to the United States Constitution, is made applicable to the States pursuant to the Fourteenth Amendment, Pointer v. Texas, 380 U. S. 400, 403 (1965), provides that *[i]n all criminal prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses against him.*