Meras v. Sisto, et al., No. 09-15399 (9th Cir. 2012)
Annotate this CasePetitioner, a California state prisoner, appealed the district court's order denying his petition for a writ of habeas corpus. Petitioner claimed that testimony introduced during his trial violated his Sixth Amendment right to confrontation. In light of the extensive, reasoned disagreement between the lower courts as to the question presented by petitioner's claim - whether forensic lab reports were testimonial - and between the Justices when they reached the issue, the court could not say that the state unreasonably applied clearly established Federal law. The court concluded that the state court probably committed constitutional error, but the court was not free to correct it under the Antiterrorism and Effective Death Penalty Act of 1996, 28 U.S.C. 2254(d). The error could have been brought before the Supreme Court in a correctable posture, had petitioner filed a cert petition after the California Supreme Court denied review in 2005. The case would have arrived at the Court nearly two years before Melendez-Diaz v. Massachusetts, and it was possible that the Court would have granted cert and decided on petitioner's case that forensic lab reports were testimonial. The Court did not decide until 2011, in Bullcoming v. New Mexico, that the right to confrontation could be satisfied only by the live testimony of a declarant.
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