Addresses “how to apply Strickland’s [Sixth Amendment ineffective assistance of counsel] prejudice test where ineffective assistance results in a rejection of the plea offer and the defendant is convicted at the ensuing trial.”
A. Kennedy
Melendez-Diaz v. Massachusetts, No. 07-591, __ U.S. __ (June 25, 2009)
Admission of government lab technicians’ sworn “certificates of analysis” that substance taken from defendant was cocaine violated defendant’s Sixth Amendment Confrontation Clause right; the certificates were “affidavits” and within the “core class of testimonial statements” defined in Crawford v. Washington.