Commonwealth v. Billings

In 2006, a jury convicted the defendant of unlawful distribution of cocaine and of a drug offense in a school zone, in violation of G. L. c. 94C, §§ 32A (c) and 32J. The Commonwealth introduced a certificate of drug analysis (certificate) without the testimony of the chemical analyst in violation of his right to confrontation pursuant to the United States Supreme Court’s decision in Melendez-Diaz v. Massachusetts, 129 S. Ct. 2527, 2532, 2542 (2009) (Melendez-Diaz). In a memorandum and order issued pursuant to its rule 1:28, the Appeals Court, relying on its decision in Commonwealth v. *363King,…