Melendez-Diaz v. Massachusetts
Is it still good law? What later courts have actually done to this case.
Status
2,800 later cases cite Melendez-Diaz v. Massachusetts; 206 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Melendez-Diaz v. Massachusetts?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The court declined to extend Melendez-Diaz's trial-stage confrontation rule to sentencing proceedings.
Wallace v. State · Arkansas Court of Appeals · filed
The United States Supreme Court has never applied the Confrontation Clause to sentencing, and the Melendez-Diaz decision does not extend that application.
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The court declined to extend Melendez-Diaz to bar an independent expert's testimony when the expert did not perform the autopsy but the autopsy report itself was not admitted.
State v. Gonzales · New Mexico Court of Appeals · filed
In the realm of Confrontation Clause analysis, we, too, refuse to extend the holdings of Crawford, Melendez-Diaz, and Bullcoming II and to toss a blanket ban on the testimony of an expert witness about the circumstances of the death of the victim in those instances when the expert did not perform the autopsy and the autopsy report has not been admitted into evidence.
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The court confined Melendez-Diaz to criminal trials and held that it did not govern confrontation rights in supervised-release revocation proceedings.
United States v. Genaro Delbosque · Fifth Circuit · filed
Contrary to Delbosque’s contention, McCormick remains good law in the wake of these cases since both Melendez-Diaz and Bullcoming pertain to a defendant’s confrontation rights in a criminal trial rather than during revocation proceedings.
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