Bullcoming v. New Mexico
2011 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Bullcoming v. New Mexico, 564 U.S. 647 (2011), is a significant 6th Amendment Confrontation Clause case decided by the United States Supreme Court. On June 23, 2011, the Supreme Court considered the issue whether a defendant's Confrontation Clause rights extend to a non-testifying laboratory analyst whose supervisor testifies as to test results that the analyst transcribed from a machine. In a five to four decision authored by Justice Ginsburg, the Court held that the second surrogate analyst could not testify about the testimonial statements in the forensic report of the certifying analyst under the Confrontation Clause.[1]
Bullcoming v. New Mexico | |
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Argued March 2, 2011 Decided June 23, 2011 | |
Full case name | Donald Bullcoming v. State of New Mexico |
Docket no. | 09-10876 |
Citations | 564 U.S. 647 (more) 131 S. Ct. 2705; 180 L. Ed. 2d 610; 2011 U.S. LEXIS 4790 |
Case history | |
Prior | Conviction affirmed, 2008 NMCA 97, 144 N.M. 546, 189 P.3d 679; affirmed, 2010 NMSC 007, 147 N.M. 487, 226 P.3d 1; cert. granted, 561 U.S. 1058 (2010). |
Holding | |
A second surrogate analyst's testimony about the statements in the forensic report of a separate certifying analyst violates the Confrontation Clause. | |
Court membership | |
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Case opinions | |
Majority | Ginsburg, joined by Scalia; Sotomayor, Kagan (all but Part IV); Thomas (all but Part IV and footnote 6) |
Concurrence | Sotomayor (in part) |
Dissent | Kennedy, joined by Roberts, Breyer, Alito |
Laws applied | |
U.S. Const. amend. VI |
The case follows a line of decisions, including Crawford v. Washington (2004) and Davis v. Washington (2006), that altered the Court's interpretation of the Confrontation Clause guarantee and clarified its application only to "testimonial" statements.