Ohio State Journal of Criminal Law

OSJCL Amici Board of Advisors

OSJCL Amici: Views from the Field

Melendez-Diaz v. Massachusetts

Issue is whether state forensic analyst’s laboratory report prepared for criminal prosecution is testimonial evidence and subject to demands of Confrontation Clause set forth in Crawford v. Washington, 541 US 36 (2004).

Petitioner in this case was arrested as part of a drug transaction in which he was the passenger in a car that another individual was spotted getting into, leaving, and being subsequently detained by officers who discovered several powders. These powders were sent to the Massachusetts Dept. of Public Health’s State Laboratory for testing. They in turn submitted a report determining that the powder was in fact cocaine. This report did not describe qualifications of experts, measures taken in testing, or percentages of cocaine. Petitioner was tried and at trial objected to the admissibility of this document without right to confront. The trial court overruled objections. This decision was affirmed by the Appeals Ct. of Massachusetts, as well as the Massachusetts Supreme Judicial court, leading to this case.



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