Facts of the Case

Luis Melendez-Diaz was arrested while making a cocaine sale in a parking lot in Massachusetts. At trial, bags of the cocaine alleged to have been distributed by Melendez-Diaz were introduced into evidence along with drug analysis certificates prepared by the lab technician who analyzed the drugs and identified them as cocaine. A jury convicted Melendez-Diaz of distributing and trafficking cocaine in violation of Massachusetts law. Melendez-Diaz appealed, arguing that the State's introduction of the drug analysis certificates violated his Sixth Amendment right to confront witnesses against him under the Court's ruling in Crawford v. Washington. Crawford had held that so-called "testimonial" evidence cannot be introduced at trial unless the defendant has a chance to cross-examine the witness providing the evidence. Melendez-Diaz characterized the lab analysis as testimonial and argued that Crawford required the lab technician to testify on the results. The State argued that Massachusetts had previously held, in Commonwealth v. Verde, that lab reports were not testimonial.

The Massachusetts Court of Appeals rejected Melendez-Diaz's claims in an unpublished opinion, referring to them in a short footnote as "without merit." The Massachusetts Supreme Court also denied his appeal.

Question

Is a state forensic analyst's laboratory report prepared for use in a criminal prosecution "testimonial" evidence subject to the demands of the Sixth Amendment's Confrontation Clause as set forth in Crawford v. Washington?

Conclusion

None