- Court: 9th Circuit Court of Appeals Archives
- Area(s) of Law: Habeas Corpus
- Date Filed: 04-23-2012
- Case #: 09-15399
- Judge(s)/Court Below: Chief Circuit Judge Kozinski for the Court; Circuit Judge Bea and District Judge Gettleman
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鈥檚 apartment was that of the victim. Lawson testified at Meras鈥檚 first trial, but was unavailable to testify at his second trial. Instead, Jill Spriggs, Lawson鈥檚 supervisor, testified to the contents of the lab report. Meras unsuccessfully objected to Spriggs鈥檚 testimony, arguing that the report was hearsay and its admission violated Meras鈥檚 Sixth Amendment right to confrontation. The California Court of Appeal affirmed the Confrontation Clause ruling, finding that the lab report was not 鈥渢estimonial鈥 under Crawford v. Washington. Meras appealed the district court鈥檚 denial of his federal habeas petition. As required by the Antiterrorism and Effective Death Penalty Act, the Ninth Circuit considered whether the state court鈥檚 ruling produced a decision that 鈥渨as contrary to, or involved an unreasonable application of, clearly established Federal law.鈥 Although Meras relied on Crawford, Melendez-Diaz v. Washington, and Bullcoming v. New Mexico, only Crawford constituted 鈥渃learly established Federal law鈥 as it was the only case decided before the Court of Appeal affirmed Meras鈥檚 conviction. The Court found that Meras failed to show that 鈥溾榯here is no possibility fairminded jurists could disagree that the state court鈥檚 decision conflicts鈥 with Crawford.鈥 This is so because the Supreme Court in Crawford expressly refused to define 鈥渢estimonial鈥 statements. Given the extensive disagreement between lower courts and among the Supreme Court Justices in considering whether forensic lab reports are 鈥渢estimonial,鈥 it cannot be said 鈥渢hat the state court unreasonably applied clearly established Federal law.鈥 Thus, the district court did not err in denying Meras鈥檚 habeas petition. AFFIRMED.