The United States Supreme Court Court case of Melendez-Diaz v. Massachusetts held that a laboratory report cannot be admitted into evidence without the lab technician testifying in person. The holding is based on the reasoning that the Confrontation Clause of the Sixth Amendment requires the lab technician testify in person.
Facts of the Case
Melendez-Diaz was suspected of perhaps drug dealing activity. The police detained him and eventually found cocaine. At trial, the prosecutor moved to admit laboratory certificates of analysis that claimed the substances found on Melendez-Diaz were cocaine. The defense objected to the admission of these certificates at trial without a lab tech there to testify, claiming the use of the lab certificates violated the Confrontation Clause per Crawford v. Washington because the lab certificates were testimonial.
The Sixth Amendment and the Confrontation Clause
The United States Constitution in the Sixth Amendment provides that “in all criminal prosecutions, the accused shall enjoy the right…to be confronted with witnesses against him.” In the case of Crawford v. Washington, the Court held that the Sixth Amendment guarantees a defendant’s right to confront those who “bear testimony” against him. The witness must appear in trial, or if the witness becomes unavailable, the defendant must have had an opportunity for prior cross examination.