Nature of the Case
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Facts
D was charged with distributing cocaine and with trafficking in cocaine. At trial, the prosecution placed into evidence the bags seized and the submitted three 'certificates of analysis' showing the results of the forensic analysis performed on the seized substances. The certificates reported the weight of the seized bags and stated that the bags 'have been examined with the following results: The substance was found to contain: Cocaine.' The certificates were sworn to before a notary public by analysts at the State Laboratory. D objected to the admission of the certificates, asserting that our Confrontation Clause decision in Crawford required the analysts to testify in person. The objection was overruled, and the certificates were admitted pursuant to state law as 'prima facie evidence of the composition, quality, and the net weight of the narcotic ... analyzed.' D was found guilty and appealed, contending that admission of the certificates violated his Sixth Amendment right to be confronted with the witnesses against him. The Appeals Court rejected the claim. The Supreme Court eventually granted certiorari.
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