Melendez-Diaz v. Massachusetts
United States Supreme Court
557 US 305 (2009)
Massachusetts (plaintiff) tried Melendez-Diaz (defendant) for cocaine distribution and trafficking, introducing sworn certificates of analysis from state crime-lab analysts to prove the seized substance was cocaine, without ever calling the analysts themselves to testify. Melendez-Diaz argued admitting these certificates without live testimony violated the Confrontation Clause, the state courts affirmed his conviction, and the Supreme Court granted certiorari after the Government offered six separate justifications for treating the certificates as non-testimonial or otherwise admissible without confrontation.
Whether the Confrontation Clause precludes admission of laboratory reports prepared by government analysts against a criminal defendant without an opportunity for cross-examination.