Crime Lab Analysis and Trials

Yesterday the United States Supreme Court issued its opinion in Melendez-Diaz v. Massachusetts, read it here.  The decision will have a major impact on criminal trials in Mississippi involving crime lab data, as the court, in an opinion penned by Justice Scalia, held that crime lab certificates may not be admitted as evidence against a defendant without the accompanying testimony of the analyst. 

The legal issue here is the defendant's right to confront his accuser set forth in the 6th Amendment.  The 6th Amendment states the following: 
In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defence.
The clause emphasized above is commonly called the "confrontation clause."  The Supreme Court based Melendez-Diaz on its previous ruling in Crawford v. Washington which held that "a witness’s testimony against a defendant is...inadmissible unless the witness appears at trial or, if the witness is unavailable, the defendant had a prior opportunity for cross-examination."

It is common practice in many Mississippi courts to admit the crime lab report without testimony from the analyst.  In some courts, if the defendant requests the analyst be present to testify the court orders that defendant to pay for the analyst's time.  The ruling in Melendez-Diaz places this burden on the State by holding that the prosecutor must produce the analyst for cross-examination.

See additional commentary from the SCOTUS Blog here and the Wall Street Journal Law Blog here.

 

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