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On June 25, 2009, a divided Supreme Court extended the reach of the Confrontation Clause in Melendez-Diaz v. Commonwealth of Massachusetts.1 In the 5-4 decision, written by Justice Antonin Scalia, the Court held that the Confrontation Clause of the Sixth Amendment bars prosecutors from using certified laboratory reports at trial in lieu of witness testimony. To get a laboratory report admitted at trial, prosecutors must now call the laboratory analyst who conducted the test and subject that witness to cross-examination at trial.

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