State v. Laturner

The opinion of the court was delivered by

Luckert, J.:

In Melendez-Diaz v. Massachusetts, 557 U.S. 305, 174 L. Ed. 2d 314, 129 S. Ct. 2527 (2009), the United States Supreme Court recently held that the admission of a forensic laboratory certificate of analysis without the testimony of the analyst, as allowed by a Massachusetts statute, violates a criminal defendant’s rights under the Confrontation Clause of the Sixth Amendment to the United States Constitution. In this case, we apply that holding to a similar Kansas statute, K.S.A. 22-3437, and determine whether the statute undermines the…