Commonwealth v. Davis

A Superior Court jury convicted the defendant of trafficking in 200 grams or more of cocaine, G. L. c. 94C, § 32E(b)(4), and doing so in a school zone, G. L. c. 94C, § 32J. On the defendant’s consolidated appeal from his convictions and from the denial of his motion for a new trial, the Commonwealth concedes that the admission of certificates of drag analysis (drug certificates) violated the defendant’s constitutional confrontation rights under Melendez-Diaz v. Massachusetts, 557 U.S. 305, 310-311 (2009) (Melendez-Diaz)■ We reject the Commonwealth’s argument that the Melendez-Diaz error was…