SUPREME COURT OF THE UNITED STATES
LUIS E. MELENDEZ-DIAZ, PETITIONER v. MASSACHUSETTS
At a state-court drug trial, the prosecution introduced certificates of state laboratory analysts stating that material seized by police and connected to petitioner was cocaine of a certain quantity. As required by state law, the certificates were sworn to before a notary public and were submitted as valid evidence of what they asserted. The Defendant objected, asserting that under Crawford v. Washington, 541 U. S. 36, it required the analysts to testify in person. The trial court disagreed, the certificates were admitted, and the Defendant was convicted. The Massachusetts Appeals Court affirmed, rejecting Defendant's claim that the certificates' admission violated his Sixth Amendment rights.
Held: The admission of the certificates violated Defendant's Sixth Amendment right to confront the witnesses against him.
(a) Under Crawford, a witness's testimony against a defendant is inadmissible unless the witness appears at trial or, if the witness is unavailable, the defendant had a prior opportunity for cross-examination. The certificates here are affidavits, which fall within the "core class of testimonial statements" covered by the Confrontation Clause. They asserted that the substance found in Defendant's possession was, as the prosecution claimed, cocaine of a certain weight-the precise testimony the analysts would be expected to provide if called at trial. Not only were the certificates made, as Crawford required for testimonial statements, "under circumstances which would lead an objective witness reasonably to believe that the statement would be available for use at a later trial," but under the relevant Massachusetts law their sole purpose was to provide genuine evidence of the substance's composition, quality, and net weight. The Defendant was entitled to "be confronted with" the persons giving this testimony at trial. ATTORNEY NOTE: The same state statute was used in drug trials in Alabama. This Supreme Court case now requires all states to provide the actual analyst to testify in court, but only if the Defendant's attorney requests it.
