Melendez-Diaz v. Massachusetts
129 S. Ct. 2527
Decided: June 5, 2009


Holding: The United States Supreme Court held that affidavits used at trial to report results of forensic analysis are “testimonial” in nature and subject to defendant’s right of confrontation under the Sixth Amendment.

Summary:
The State charged Melendez-Diaz with distributing and trafficking in co¬caine. At trial, the prosecution submitted into evidence affidavits signed by state laboratory analysts which certified that the substance in question was cocaine. Melendez-Diaz objected to the admission of the affidavits alleging that it violated his right under the Sixth Amendment to confront the analysts. Under Massachusetts law, authors of “certificates” of forensic analysis are not subject to confrontation under the Sixth Amendment. Mass. Gen. Laws, ch. 111,§ 13. The court of appeals agreed.

However, the United States Supreme Court found that the documents in question were not just certificates but were affidavits made for the purpose of establishing or proving the fact that the substance in Melendez-Diaz’s possession was cocaine. Affidavits fall into the category of “testimonial statements” and the analysts are “witnesses,” and therefore are subject to the Confrontation Clause. The Court stated that under Crawford v. Washington, a “witness’s testimony against a defendant is thus inadmissible unless the witness appears at the trial or, if the witness is unavailable, the defendant has had a prior opportunity for cross-examination.” 541 U.S. 36, 54, 124 S. Ct. 1354. In Crawford, the Court described the type of testimonial statements covered by the Confrontation Clause. These statements include, “ex parte in-court testimony or its functional equivalent, that is, material such as affidavits.” In Melendez-Diaz, the “certificates” are the functional equivalent to live-in-court testimony. The Sixth Amendment does not allow the prosecution to prove its case via ex parte out-of-court affidavits, and therefore the admission of the evidence against Melendez-Diaz violated his constitutional rights.