Thursday, December 5, 2013

Melendez-Diaz v. Massachusetts case brief

Melendez-Diaz v. Massachusetts case brief summary
129 S.Ct. 2527 (2009)

Petitioner defendant appealed his convictions for distributing cocaine and trafficking in cocaine, in violation of Mass. Gen. Laws ch. 94C, §§ 32A and 32E(b)(1), contending that respondent Commonwealth of Massachusetts violated his rights under the U.S. Constitution. The Appeals Court of Massachusetts affirmed the conviction and the Supreme Judicial Court of Massachusetts denied review. The U.S. Supreme Court granted certiorari.

Petitioner 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), and the prosecution offered certificates signed by state laboratory analysts which stated that evidence that was connected to petitioner was cocaine. Petitioner 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, but the trial court overruled the objection and admitted the certificates under Mass. Gen. Laws ch. 111, § 13.


  • 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. 
  • Although petitioner 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. 5-4 Decision; 1 Concurring Opinion; 1 Dissent.

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