Melendez-Diaz v. Massachusetts

The Commonwealth of Massachusetts (the Government) (plaintiff) tried Melendez-Diaz (defendant) for distributing and trafficking in cocaine. At trial, the Government introduced “certificates of analysis,” prepared by analysts in the State Crime Laboratory, in order to show that the substance seized from Melendez-Diaz was cocaine. The analysts did not testify at trial. On appeal, Melendez-Diaz asserted that the certificates of analysis were testimonial and their admission by the trial court violated his constitutional rights under the Confrontation Clause. The Massachusetts Court of Appeals affirmed and Melendez-Diaz appealed to the United States Supreme Court. On appeal in the Supreme Court, the Government presented six grounds for finding that admission of the certificates did not implicate or violate the Confrontation Clause. First, the witnesses were not accusatory because the information in the certificates did not directly accuse Melendez-Diaz of wrongdoing. Second, the analysts’ statements in the certificates were not the type of ex parte statements presented in the trial of Sir Walter Raleigh. Third, Melendez-Diaz would not derive a benefit from having the opportunity to cross-examine on the “neutral, scientific testing” contained in the certificates. Fourth, the certificates are admissible as business or public records under the common law. Fifth, Melendez-Diaz could have subpoenaed the analysts. Sixth, stringent application of the Confrontation Clause in this case will make the prosecution of criminals overly burdensome because analysts will have to testify any time scientific data is presented.