Melendez-Diaz Supreme Court Decision Affects Forensic Laboratories

Luis Melendez-Diaz was arrested for selling cocaine in Massachusetts. A bag of cocaine was introduced as evidence. The cocaine was analyzed in a forensic laboratory. Therefore, the drug analysis was also introduced as evidence.

Melendez-Diaz was convicted of distributing and trafficking cocaine. Melendez-Diaz decided to appeal because his Sixth Amendment right was violated because he was not allowed to confront the analyst who performed the drug analysis. This case went all the way to the Supreme Court.

Melendez-Diaz argued that the “testimonial” evidence cannot be introduced at trial unless he had the chance to cross-examine whoever provided the evidence—this came from Crawford v. Washington. Melendez-Diaz considered the drug analysis information as testimonial. The state argued that the evidence was not testimonial because it was previously held in Commonwealth v. Verde.

The core question of this case is: are forensic laboratory reports testimonial evidence subject to the confrontation clause of the Sixth Amendment?

The Supreme Court, in a 5-4 decision, sided with Melendez-Diaz. Therefore, since Melendez-Diaz was not allowed to cross-examine the analyst, his Sixth Amendment rights were violated.

This court decision will create many implications for forensic laboratories. This means many analysts will be called to testify, taking them away from the massive amount of work they have.

There are several posed solutions to this. The first solution is expanded pretrial discovery. This means that the defense would be allowed to examine the strength of the forensic evidence earlier, and would allow then to build a stronger case. The next proposed solution is using court-appointed experts to analyze the evidence and the expert would be allowed to make recommendations to the judge based on the reliability and admissibility of the evidence. There are several other proposed solutions such as demonstrable reliability, rules of weight and sufficiency of the evidence, and mandatory accreditation and certification.

This case has changed the implications of forensic laboratories in court cases forever and will continue to be criticized until a permanent solution is made.

Melendez-Diaz v. Massachusetts.  557 U.S. 305 (2009).

Forensic Summary by Marissa Felinczak


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