Melendez-Diaz v. Massachusetts
E821196
Melendez-Diaz v. Massachusetts is a 2009 U.S. Supreme Court decision holding that forensic laboratory reports are testimonial evidence and that defendants have a Sixth Amendment right to confront the analysts who prepared them.
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
Confrontation Clause case
ⓘ
United States Supreme Court case ⓘ criminal procedure case ⓘ |
| areaOfLaw |
constitutional law
ⓘ
criminal law ⓘ evidence law ⓘ |
| arguedDate | November 10, 2008 ⓘ |
| citation | 557 U.S. 305 ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | June 25, 2009 ⓘ |
| decisionType | 5–4 decision ⓘ |
| dissentingOpinionBy | Justice Anthony M. Kennedy NERFINISHED ⓘ |
| docketNumber | No. 07-591 ⓘ |
| holding |
Admission of sworn forensic certificates without live testimony violates the Confrontation Clause unless the analyst is unavailable and the defendant had a prior opportunity for cross-examination.
ⓘ
Defendants have the right to confront and cross-examine the analysts who prepare forensic laboratory reports used against them at trial. ⓘ Forensic laboratory certificates reporting the results of drug analysis are testimonial statements under the Confrontation Clause of the Sixth Amendment. ⓘ |
| impact |
Required live testimony or prior cross-examination of forensic analysts whose reports are used as evidence.
ⓘ
Strengthened defendants' confrontation rights regarding forensic evidence. ⓘ |
| issue |
Whether certificates of state laboratory analysts identifying a substance as cocaine are testimonial evidence.
ⓘ
Whether the prosecution may introduce forensic lab reports without calling the analysts as witnesses. ⓘ |
| joinedByInDissent |
Chief Justice John G. Roberts Jr.
NERFINISHED
ⓘ
Justice Samuel A. Alito Jr. NERFINISHED ⓘ Justice Stephen G. Breyer NERFINISHED ⓘ |
| joinedByInMajority |
Justice Clarence Thomas
NERFINISHED
ⓘ
Justice David H. Souter NERFINISHED ⓘ Justice John Paul Stevens NERFINISHED ⓘ Justice Ruth Bader Ginsburg NERFINISHED ⓘ |
| jurisdiction |
Massachusetts
ⓘ
surface form:
Commonwealth of Massachusetts
|
| legalProvisionInterpreted |
Confrontation Clause
NERFINISHED
ⓘ
Sixth Amendment to the United States Constitution NERFINISHED ⓘ |
| majorityOpinionBy | Justice Antonin Scalia NERFINISHED ⓘ |
| page | 305 ⓘ |
| party |
Commonwealth of Massachusetts
NERFINISHED
ⓘ
Luis E. Melendez-Diaz NERFINISHED ⓘ |
| relatedToCase |
Bullcoming v. New Mexico
NERFINISHED
ⓘ
Crawford v. Washington NERFINISHED ⓘ Williams v. Illinois NERFINISHED ⓘ |
| reporter | United States Reports ⓘ |
| result | Conviction reversed and case remanded. ⓘ |
| stateProcedureChallenged | Massachusetts practice of admitting sworn drug analysis certificates without analyst testimony ⓘ |
| subsequentCitationFrequency | frequently cited in Confrontation Clause jurisprudence ⓘ |
| topic |
criminal prosecutions involving drug analysis
ⓘ
forensic science evidence ⓘ testimonial evidence ⓘ |
| volume | 557 ⓘ |
| yearDecided | 2009 ⓘ |
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.