Meras v. Sisto

A state court’s admission of a non-testifying expert’s lab report into evidence on the basis that it is not “testimonial” under Crawford is not “an unreasonable application of Federal law,” and therefore does not trigger a defendant’s right to confrontation under the Sixth Amendment.

California state prisoner, Edward Meras, was convicted of robbery, burglary and assault with a deadly weapon in state court. Jennai Lawson, a forensic expert, produced a lab report confirming that blood found on clothing in Meras’s apartment was that of the victim. Lawson testified at Meras’s first trial, but was unavailable to testify at his second trial. Instead, Jill Spriggs, Lawson’s supervisor, testified to the contents of the lab report. Meras unsuccessfully objected to Spriggs’s testimony, arguing that the report was hearsay and its admission violated Meras’s Sixth Amendment right to confrontation. The California Court of Appeal affirmed the Confrontation Clause ruling, finding that the lab report was not “testimonial” under Crawford v. Washington. Meras appealed the district court’s denial of his federal habeas petition. As required by the Antiterrorism and Effective Death Penalty Act, the Ninth Circuit considered whether the state court’s ruling produced a decision that “was contrary to, or involved an unreasonable application of, clearly established Federal law.” Although Meras relied on Crawford, Melendez-Diaz v. Washington, and Bullcoming v. New Mexico, only Crawford constituted “clearly established Federal law” as it was the only case decided before the Court of Appeal affirmed Meras’s conviction. The Court found that Meras failed to show that “‘there is no possibility fairminded jurists could disagree that the state court’s decision conflicts’ with Crawford.” This is so because the Supreme Court in Crawford expressly refused to define “testimonial” statements. Given the extensive disagreement between lower courts and among the Supreme Court Justices in considering whether forensic lab reports are “testimonial,” it cannot be said “that the state court unreasonably applied clearly established Federal law.” Thus, the district court did not err in denying Meras’s habeas petition. AFFIRMED.