certificates of drug analysis (Massachusetts) · Go Syfert
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certificates of drug analysis in Massachusetts

8 Massachusetts opinions name it 2 courts 2010–2016 0 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Melendez-Diaz v. Massachusettsgreen
scotus · 2009 · cited in 2 Massachusetts opinions naming this issue, 2010–2011
2 sentences

2011See Melendez-Diaz v. Massachusetts, 129 S. Ct. 2527 (2009); Commonwealth v. Vasquez , 456 Mass, at 358-359.

2010As held by the United States Supreme Court in Melendez-Diaz v. Massachusetts, 129 S. Ct. 2527 (2009), the admission of the certificates of drug analysis to meet the Commonwealth’s burden, without affording the defendants the opportunity to cross-examine the chemical analyst who prepared them, violated the defendants’ rights under the confrontation clause of the Sixth Amendment to the United States Constitution.

12
Fahy v. Connecticutgreen
scotus · 1963 · cited in 1 Massachusetts opinions naming this issue, 2011–2011
1 sentence

2011Indeed, as the case was conceived, tried, argued, and instructed, there was no “reasonable possibility that the evidence complained of might have contributed to the conviction.” Chapman v. California, 386 U.S. 18, 23 (1967), quoting from Fahy v. Connecticut, 375 U.S. 85, 86-87 (1963).

11
Chapman v. Californiared
scotus · 1967 · cited in 1 Massachusetts opinions naming this issue, 2011–2011
1 sentence

2011Indeed, as the case was conceived, tried, argued, and instructed, there was no “reasonable possibility that the evidence complained of might have contributed to the conviction.” Chapman v. California, 386 U.S. 18, 23 (1967), quoting from Fahy v. Connecticut, 375 U.S. 85, 86-87 (1963).

11
Commonwealth v. Streetgreen
mass · 1983 · cited in 1 Massachusetts opinions naming this issue, 2011–2011
1 sentence

2011However, as we conclude that the defendant is entitled to a new trial on that charge as a result of the erroneous admission of the certificates of drug analysis, we have no reason to address what implications, if any, might arise from the defendant being “denuded of a defense.” Commonwealth v. Street, 388 Mass. 281, 287 (1983).

11
Commonwealth v. Tyreegreen
mass · 2010 · cited in 1 Massachusetts opinions naming this issue, 2010–2010
2 sentences

2010I also agree that an appellate court must ask whether “on the totality of the record before us, weighing the properly admitted and the improperly admitted evidence together, we are satisfied beyond a reasonable doubt that the tainted evidence did not have an effect on the [fact finder] and did not contribute to the [fact finder’s findings].” Commonwealth v. Tyree, 455 Mass. 676, 701 (2010).

2010I also agree that an appellate court must ask whether "on the totality of the record before us, weighing the properly admitted and the improperly admitted evidence together, we are satisfied beyond a reasonable doubt that the tainted evidence did not have an effect on the [fact finder] and did not contribute to the [fact finder's findings]." Commonwealth v. Tyree, 455 Mass. 676, 701 (2010).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Commonwealth v. Scott green
mass · 2014
2 sentences

2016Years later, after Dookhan's misconduct had been discovered, see generally Commonwealth v. Scott, 467 Mass. 336 (2014), the defendant unsuccessfully moved for a new trial, seeking to vacate his guilty pleas on the ground of Dookhan's misconduct.

2015The present case is the latest in a series of cases concerning the egregious misconduct of Annie Doolchan, a chemist who was employed in the forensic drug laboratory of the William A. Hinton State Laboratory Institute (Hinton drug lab) *467 from 2003 until 2012. 3 Kevin Bridgeman, Yasir Creach, and Miguel Cuevas (collectively, the petitioners) are three individuals who pleaded guilty to various drug offenses in cases where Dookhan signed the certificates of drug analysis (drug certificates) on the line labeled “Assistant Analyst.” On January 9, 2014, prior to this court’s decision in Commonwea

22015–2016
Commonwealth v. Verde green
mass · 2005
2 sentences

2011The defendant’s trial occurred after the decision in Commonwealth v. Verde, 444 Mass. 279 (2005), but before the issuance of the opinion in Melendez-Diaz by the United States Supreme Court.

2010Although the defendants did not object, on confrontation grounds, to the admission of the certificates at trial, because their case was tried after the Supreme Judicial Court’s decision in Commonwealth v. Verde, 444 Mass. 279 (2005), and before the issuance of Melendez-Diaz , they are entitled to have this constitutional error reviewed under the “harmless beyond a reasonable doubt” standard.

22010–2011
Commonwealth v. Charros green
mass · 2005
1 sentence

2011We also determined this result was fair because it was virtually impossible to discern if the defendants’ motivation to testify was independent of the erroneous admission of the certificates of drug analysis, relying upon Commonwealth v. Charros, 443 Mass. 752 , cert, denied, 546 U.S. 870 (2005).

12011–2011
Stevens v. State Bar green
scotus · 2005
1 sentence

2011We also determined this result was fair because it was virtually impossible to discern if the defendants’ motivation to testify was independent of the erroneous admission of the certificates of drug analysis, relying upon Commonwealth v. Charros, 443 Mass. 752 , cert, denied, 546 U.S. 870 (2005).

12011–2011
Crawford v. Washington green
scotus · 2004
1 sentence

2010The defendant states in a single paragraph in his brief that, although he made no objection, the introduction of three certificates of drug analysis in his July, 2004, trial violated his confrontation rights as set forth in Crawford v. Washington, 541 U.S. 36 (2004).

12010–2010

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 94C, § 32A (5) MA § Mass. Gen. Laws ch. 94C, § 32J (4) MA § Mass. Gen. Laws ch. 94C, § 32E (3) MA § Mass. Gen. Laws ch. 94C, § 34 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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