At defendant’s state court drug trial, the prosecution introduced certificates of state laboratory analysts stating that the cocaine seized by police and connected to him was of a certain quantity. As required by Massachusetts law, the certificates were sworn to before a notary public and submitted as prima facie evidence of what they asserted. Defendant objected on the basis that Crawford v. Washington required the analysts to testify in person.
The trial court disagreed, the certificates were admitted, and petitioner was convicted. The Massachusetts Appeals Court affirmed, rejecting petitioner’s claim that the certificates’ admission violated the Sixth AmendmentThe U.S. SUPREME COURT held in MELENDEZ-DIAZ v. MASSACHUSETTSon June 25, 2009that the admission of the certificates violated defendant’s Sixth Amendment right to confront the witnesses against him.
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