From our private database of 14,200+ case briefs...
Melendez-Diaz v. Massachusetts
United States Supreme Court
129 S.Ct. 2527 (2009)
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.
Rule of Law
Holding and Reasoning (Scalia, J.)
Concurrence (Thomas, J.)
Dissent (Kennedy, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 238,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,200 briefs, keyed to 189 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.