2. Overview. Melendez-Diaz v. MassachusettsVirginia\'s Recent LegislationTwo-way Video Testimony in Criminal TrialsDiscussion. 3. Melendez-Diaz v. Massachusetts. In Melendez-Diaz v. Massachusetts, 557 U.S. __ , 129 S. Ct. 2527 (2009), the Supreme Court held that certificates of analysis prepared by laboratories in drug cases are testimonial.Therefore, they cannot be admitted into evidence in criminal cases without the presence of the person who prepared or attested to the facts 35750
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