Commonwealth v. King

In 2008, in a bifurcated, jury-waived trial, the defendant was convicted of unlawful distribution of cocaine, in violation of G. L. c. 94C, § 32A (c), and as a subsequent offense, G. L. c. 94C, § 32A (d).1 As proof that the substance was cocaine, the Commonwealth introduced a certificate of drug analysis (certificate) and the testimony of a police detective who stated that a field test he had conducted was positive. On *355appeal, the defendant claimed that, pursuant to the United States Supreme Court’s decision in Melendez-Diaz v. Massachusetts, 129 S. Ct. 2527, 2532, 2542 (2009)…