Supreme court of the united states syllabus melendezdiaz v. Massachusetts on admissibility of forensic test results at courtsmartial. Mass from fs 240 at western new england university. At the trial court, the evidence introduced included bags of cocaine that were alleged to have been sold by melendezdiaz and the drug analysis certificates that the lab technician prepared when. The united states supreme court decided melendezdiaz v. Jun 06, 2014 with that finding, the golden states camera programs no longer need to worry about legal challenges based on the series of us supreme court decisions, beginning in 2009 with melendez diaz v. The defendant, diaz, was an employee of a boston kmart in 2001 when a tip was called in to the boston police department that he was acting strangely. Introduction the latest development in the saga of the ever encompassing confrontation clause comes from the supreme court, via a fivefour vote, in the case of melendezdiaz v. Montero and the defendant were tried together under a joint venture theory.
Machinegenerated data and the confrontation clause digital. Massachusetts that defendants have a right to crossexamine forensic laboratory analysts in criminal cases. Massachusetts on writ of certiorari to the appeals court ofmassachusetts june 25, 2009 justice kennedy, with whom the chief justice, justice breyer, and justice alito join, dissenting. Karlan salem, ma 01970 stanford law school supreme. Massachusetts audio transcription for opinion announcement june 25, 2009 in melendezdiaz v. Melendez diaz appealed, arguing that the states introduction of the drug analysis certificates violated his sixth amendment right to confront witnesses against him under the courts ruling in crawford v. Melendezdiaz was charged with distributing cocaine and with trafficking in. The lexis pagination of this document is subject to change pending release of the final published version.
Last week, judge digirolamo signed an opinion interpreting the supreme courts recent decision in melendezdiaz v. Court concluded that a certificate of chemical analysis, sworn to by a state laboratory analyst and reporting the weight and chemical makeup of a seized substance, came within the class of testimonial statements subject to the protections of the confrontation clause of. The police were informed that diaz would receive phone calls at work and would then be picked up in front of the store and return a short time later. Much testimony was directed at estimating the street selling prices of the packages. Syllabus opinion scalia concurrence thomas dissent kennedy html version pdf version.
Massachusetts, 557 us 305 2009, including the facts, issue, rule of law, holding and reasoning, key terms, and concurrences and dissents. The admissibility the melendezdiaz,andwilliams cases. Contrary to the dissents suggestion, post, at 2555, we do not rely in such great measure on the deficiencies of crimelab analysts shown by this report to resolve the constitutional question presented in this case. Massachusetts, the legislation virginia enacted in response to the case during the special session of 2009, and the possibility of using videoconferencing during. I will cover this case following davis because melendez represents the last word on this subject from the supreme court, and because this is the first major case in the crawford. Jun 26, 2009 in yesterdays frivolous post, i said that legal news was slow. Fall 2010 melendezdiaz and the confrontation clause 123 courts had to wait until 2006, two years after crawford, once davis v. Massachusetts 3 that the confrontation clause of the sixth amendment to the united states constitution puts the burden on. In melendezdiaz, the massachusetts courts permitted the prosecution to prove the. Melendezdiaz appealed, arguing that the states introduction of the drug analysis certificates violated his sixth amendment right to confront witnesses against him under the courts ruling in crawford v. The melendezdiaz, bullcoming,andwilliams cases facts and issues summarized melendezdiaz v.
New mexico, justin mcshane speaking engagements, melendezdiaz v. Argued november 10, 2008decided june 25, 2009 at petitioners statecourt drug trial, the prosecution introduced certifi. Massachusetts supreme court of the united states, 6252009 permanent link for this item return to front page. Massachusetts view ruling, holding that the individual who does lab analysis of evidence can be called to testify about his findings in court.
Military and naval science confrontation criminal law laws, regulations and rules confrontation law court martial courtsmartial and courts of inquiry evidence, expert evidence, scientific expert evidence scientific evidence law. Luis melendezdiaz was arrested while making a cocaine sale in a parking lot in massachusetts. Ensuring scientific validity of feature comparison methods. Melendezdiaz appealed, arguing that the states introduction of the drug analysis certificates violated his sixth amendment right to confront witnesses against him. Nov 10, 2008 the appeals court of massachusetts rejected the claim, affirmance order, 69 mass.
Massachusetts audio transcription for oral argument november 10, 2008 in melendezdiaz v. This case involves the application of the confrontation clause of the sixth amendment to police laboratory reports. The future of the confrontation clause joseph henn1 i. Jul 31, 2009 a copy of the supreme court decision is available in a 350k pdf file at the source link below. Appeals court of massachusetts july 31, 2007 confrontation clause, sixth amendment, crawford v. In yesterdays frivolous post, i said that legal news was slow. Because i conclude that the supreme courts decision in melendezdiaz v. Recommended citation ryan sullivan, the aftermath of melendezdiaz v. A copy of the supreme court decision is available in a 350k pdf file at the source link below. Supreme court revisited an issue it appeared to resolve just months before whether the prosecution in dui and other. But since jessies still busy administering the superior court judges. Audio transcription for oral argument november 10, 2008 in melendezdiaz v.
Audio transcription for opinion announcement june 25, 2009 in melendezdiaz v. The analysts who swore the affidavits provided testimony against melendezdiaz, and they are therefore subject to confrontation. On writ of certiorari to the appeals court of massachusetts brief of amicus curiae the national innocence network in support of petitioner timothy p. We conclude that the proof submitted was consistent with the sixth amendment as recently detailed in melendezdiaz v. Lexis 4734 november 10, 2008, argued june 25, 2009, decided notice. Roberts, jr justice scalia has our opinion this morning in case 07591, melendezdiaz versus massachusetts. Hoffman in 1943 i think lays that out very, very clearly. Massachusettsa in 2001, after setting up surveillance of a suspected drug transaction, police of. Supreme court ruling requiring prosecutors to put chemists on the witness stand to certify their lab reports is causing delays and headaches in courtrooms across the state. In melendezdiaz, the court held that state forensic analysts certificates of analysis performed on seized substances, and prepared for. Massachusetts massachusetts pennsylvania dui attorney wins appeal in the superior court of pennsylvania. Luis melendez diaz was arrested after being observed making a cocaine sale in a massachusetts parking lot.
In melendezdiaz, the court held that state forensic analysts certificates of analysis performed on seized substances, and prepared for use in criminal prosecutions are testimonial evidence, and subject to confrontation as set. The officers placed all three men in a police cruiser. Its a big confrontation clause case, and i expect that jessica smith, the crawford expert on our faculty, will eventually weigh in with an expert analysis. Virginia getting the evidentiary nature of bac test results for dui prosecutions right the second time around. Appellant objected, arguing admission of the certificates would violate her rights under the confrontation clause of the sixth amendment,2 as delineated in melendez diaz v. Virginia decision, in which the supreme court declined to disturb melendezdiaz or provide a rule regarding noticeanddemand statutes. Massachusetts certiorari to the appeals court of massachusetts no. It is well settled that the right to confrontation may be waived by failing to object to the offending evidence. Supreme court ruled by a 5to4 vote in the case of melendezdiaz v. President barack obamas hilarious final white house correspondents dinner speech duration. Absent a showing that the analysts were unavailable to testify at trial and that petitioner had a prior opportunity to crossexamine them, petitioner was entitled to be confronted with the analysts at trial, quoting from crawford v. Because i conclude that the supreme courts decision in melendez diaz v. A jury convicted melendez diaz of distributing and trafficking cocaine in violation of massachusetts law.
Massachusetts, the court applied this rule to forensic evidence, holding that certificates of analysisused in a drug trial to prove the nature and weight of the proscribed substances, and sworn to and signed by the analysts who performed the testsare testimonial. Massachusetts united states supreme court 2009 wl 1789468 2009 justice scalia delivered the opinion of the court. Forensic laboratory reports are testimonial and thus subject to the rule of crawford v. Brief of respondent massachusetts in opposition filed. The massachusetts appeals court affirmed, rejecting petitioners claim that the. The court sweeps away an accepted rule governing the admission of scientific evidence. During the short drive to the police station, the officers observed their passengers fidgeting and making furtive movements in the back of the car. Massachusetts, the supreme court concluded that a certificate of chemical analysis, sworn to by a state laboratory analyst and reporting the weight and chemical makeup of a seized substance, came within the class of testimonial statements subject to the protections of the confrontation clause of the sixth amendment. A jury convicted melendezdiaz of distributing and trafficking cocaine in violation of massachusetts law.
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