Facts: In 2001, an informant called the Boston police informing them illegal activity could be occurring at Kmart. The informant stated that an employee would receive calls at work, would leave in a blue sedan, and then later return. Police detained and searched the employee finding four clear plastic bags containing a white powdery substance, alleged to be cocaine. Police detained and searched all passengers of the blue sedan including Luis Melendez-Diaz, and took them down to police headquarters. During the ride to the police headquarter, the police officer noticed movements. Upon arrival at the station, police searched the interior of the car and found 19 small packets that contained white powder substance. Police submitted all alleged contraband for chemical testing and Melendez-Diaz was charged with distribution and drug trafficking of cocaine in an amount between 14 and 28 grams under the Massachusetts Controlled Substances Act.
Determination of the court: A jury trial found Melendez-Diaz guilty.
Legal reasoning or rationale used by the court to reach their decision: " Various formulations of this core class of testimonial statements exist: ex parte in-court testimony or its functional equivalent — that is, material such as affidavits, custodial examinations, prior testimony that the defendant was unable to cross-examine, or similar pretrial statements that declarants would reasonably expect to be used prosecutorially; extra-judicial statements . . . contained in formalized testimonial materials, such as affidavits, depositions, prior testimony, or confessions; statements that were made under circumstances which would lead an objective witness reasonably to believe that the statement would be available for use at a later trial."
Implications of the ruling on the conduct of criminal justice: At the trial, the prosecution placed into evidence the bags seized from Wright (defendants co-worker) and from the police cruiser in which the defendant and Wright were making moving motions in. The prosecutor also submitted three "certificates of analysis" showing the results of the forensic analysis performed on the seized substances. The results of the substance came back positive for cocaine. The involvement that the defendant intended to argue was he did not commit the crime or shared the intent to commit the crime, and did not know that any transaction were going to take place. The Prosecutor has to prove the defendant guilty of trafficking on a joint venture theory, the underlying crime of trafficking in cocaine was committed, and that the elements of joint venture was committed.
Forensic Evidence 2: Williams vs. Illinois, No 10-8505
Facts: Sandy Williams was convicted of two counts of aggravated criminal sexual assault and one count each of aggravated kidnapping and aggravated robbery. Illinois court affirmed Williams' conviction but changed it to a consecutive sentence. On appeal to the Illinois Supreme Court, the defendant argued that the testimony of an Illinois State Police forensic analyst, who relied upon the results of a third-party analyst for DNA, whom were not there to testify against him, lacked a sufficient evidentiary foundation. Alternatively, Williams argued that this testimony concerning the report was hearsay presented for the truth of the matter and violated the defendant's Sixth Amendment Confrontation Clause right. The state’s high court affirmed that, Williams' Sixth Amendment rights weren't violated.
Determination of the court: The trial court found petitioner guilty of the charges against him.
Legal reasoning or rationale used by the court to reach their decision: The Court took the view that the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule. An expert witness may voice an opinion based on facts concerning the events at issue even if