Bullcoming v. New Mexico

E821197

Bullcoming v. New Mexico is a 2011 U.S. Supreme Court case that clarified the Confrontation Clause by holding that defendants have the right to cross-examine the specific analyst who prepared a forensic laboratory report used as evidence against them.

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Statements (49)

Predicate Object
instanceOf Confrontation Clause case
United States Supreme Court case
criminal procedure case
areaOfLaw constitutional criminal procedure
criminal law
evidence law
arguedDate 2011-03-02
caseOutcome Judgment of the New Mexico Supreme Court reversed
citation 564 U.S. 647
concurrenceBy Sonia Sotomayor NERFINISHED
concurrenceType concurring in part
concurring in the judgment
constitutionalProvision Confrontation Clause NERFINISHED
Sixth Amendment to the United States Constitution NERFINISHED
court Supreme Court of the United States
decisionDate 2011-06-23
decisionType 5–4 decision
dissentBy Anthony M. Kennedy NERFINISHED
dissentJoinedBy John G. Roberts Jr. NERFINISHED
Samuel A. Alito Jr. NERFINISHED
Stephen G. Breyer NERFINISHED
docketNumber 09-10876
factPattern The case involved admission of a blood-alcohol concentration report in a DWI prosecution without testimony from the analyst who performed the test.
fullName Bullcoming v. New Mexico NERFINISHED
holding Surrogate testimony by another analyst who did not perform or observe the test is insufficient to satisfy the Confrontation Clause when the report is testimonial.
The Confrontation Clause requires that the prosecution present the testimony of the analyst who certified a forensic laboratory report unless that analyst is unavailable and the defendant had a prior opportunity for cross-examination. NERFINISHED
issue Whether the prosecution may introduce a forensic laboratory report through the in-court testimony of a scientist who did not sign the certification or perform or observe the test.
joinedByInMajority Antonin Scalia NERFINISHED
Clarence Thomas NERFINISHED
Elena Kagan NERFINISHED
Sonia Sotomayor NERFINISHED
jurisdiction United States of America
surface form: United States
keyword forensic evidence
laboratory analyst testimony
surrogate expert testimony
testimonial statements
lowerCourt Supreme Court of New Mexico NERFINISHED
majorityOpinionBy Ruth Bader Ginsburg NERFINISHED
originatingJurisdiction State of New Mexico NERFINISHED
page 647
party Donald Bullcoming NERFINISHED
State of New Mexico NERFINISHED
relatedTo Crawford v. Washington NERFINISHED
Melendez-Diaz v. Massachusetts NERFINISHED
Williams v. Illinois NERFINISHED
reporter United States Reports
subjectMatter admissibility of forensic laboratory reports
right to confrontation of witnesses
volume 564

Referenced by (1)

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Crawford v. Washington subsequentCaseInterpreting Bullcoming v. New Mexico