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.
SCOTUS
Montejo v. Arizona, No. 07-1529, __ U.S. __ (May 26, 2009)
Overrules Michigan v. Jackson holding that once a suspect has claimed the Sixth Amendment right to a lawyer, any later waiver of that right during police questioning would be invalid, unless the suspect initiates communication with the officers.
Arizona v. Gant, No. 07-542, __ U.S. __ (April 21, 2009)
Police may search a vehicle incident to a recent occupant’s arrest only if the arrestee is within reaching distance of the passenger compartment at the time of the search or it is reasonable to believe the vehicle contains evidence of the offense of arrest.
Rivera v. Illinois, No. 07-9995, __ U.S. __ (Mar. 27, 2009)
State law, not the Constitution, determines the consequences of an erroneous denial of a peremptory challenge, when all jurors selected are qualified and unbiased.
Wyeth v. Levine, No. 06-1249, ___ U.S. ___ (Mar. 4, 2009) (excerpts from syllabus)
Federal law does not pre-empt plaintiff’s claim that a drug label approved by the FDA did not contain an adequate warning about a particular method of administration.