Case Exposition of Melendez Diaz V Massachusetts 557 U S 305 2009

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Melendez-Diaz v. Massachusetts 557 U.S. 305 (2009), police arrested Luis Melendez-Diaz as the defendant was making an illegal cocaine sale in a Kmart parking lot in Massachusetts. During the trial, the Court brought into evidence, bags of cocaine Melendez-Diaz allegedly distributed along with approved drug analysis certificates a certified lab technician prepared. The lab technician also examined the drugs, identifying them as the illegal substance, cocaine and testified it was cocaine in Court. While Melendez-Diaz sought to enter a plea of not-guilty, a jury convicted Melendez-Diaz of trafficking and distributing cocaine in direct violation of Massachusetts law.

Melendez-Diaz appealed as he felt when the State introduced the drug analysis certificates performed by the lab technician, it violated his Six Amendment right that consisted of confronting witnesses against him using the Court's ruling in another case, Crawford v. Washington. In the Crawford ruling, it was held that so-called "testimonial" proof cannot be presented at trial without the defendant having an opportunity to cross-examine any witness providing such evidence. Melendez-Diaz considered the lab examination as testimonial arguing that Crawford made it necessary for the lab technician to bear witness on the results. The State's counterargument referred to another case and ruling, Commonwealth v. Verde in which the state of Massachusetts had previously held that lab reports were not considered as testimonial and therefore removes the requirement of cross-examination on the part of the defendant.

In an unpublished opinion, the Massachusetts Court of Appeals overruled Melendez Diaz's claims referring to them as a 'short footnote' of which contained no merit. Melendez Diaz's appeal was also denied by the Massachusetts Supreme Court although the Supreme Court recognized that the lab report submitted by the state forensic analyst for use within a criminal prosecution setting can be subjected to the demands of the Confrontation Clause in the Sixth Amendment, therefore making the lab reports 'testimony', or 'core class of testimonial statements'.

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When the Court was not allowed to confront the lab technician, the Court violated Melendez-Diaz's Sixth Amendment right.

The Massachusetts Court of Appeals rejected Melendez-Diaz's claims in an unpublished opinion, referring to them in a short footnote as "without merit." The Massachusetts Supreme Court also denied his appeal. The Supreme Court held that a state forensic analyst's lab report that is prepared for use in a criminal prosecution is subject to the demands of the Sixth Amendment's Confrontation Clause. With Justice Antonin G. Scalia writing for the majority and joined by Justices John Paul Stevens, David H. Souter, Clarence Thomas, and Ruth Bader Ginsburg, the Court reasoned that the lab reports constitute affidavits which fall within the "core class of testimonial statements" covered by the Confrontation Clause. Therefore, when Mr. Melendez- Diaz was not allowed to confront the persons who created the lab reports used in testimony at his trial, his Sixth Amendment right was violated. There was dissention among the Justices as Justice Kennedy, Justice Robert, Justice Breyer, and Justice Alito because of the nature of the testimony and the consideration of scientific analysis not needing testimony to introduce it into evidence. However, in the end, through a 'notice-and-demand'….....

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