Crawford v. Washington
Citation: 541 U.S. 36 (U.S. Supreme Court, 2004)
Facts
Michael Crawford was charged with assault. His wife Sylvia witnessed the stabbing but invoked the marital privilege at trial. The prosecution introduced a recorded statement Sylvia had given to police during interrogation, which was potentially incriminating to Michael. Crawford argued that admitting the statement without the ability to cross-examine his wife violated the Confrontation Clause.
Issue
Whether the Confrontation Clause permits the admission of a testimonial statement by a declarant who is unavailable to testify, when the defendant had no prior opportunity to cross-examine the declarant.
Holding
The Supreme Court held that the admission of Sylvia’s recorded police interrogation statement violated the Confrontation Clause. Testimonial statements of witnesses absent from trial may only be admitted where the declarant is unavailable and the defendant had a prior opportunity for cross-examination.
Rule
The Confrontation Clause bars “testimonial” out-of-court statements unless the declarant is unavailable and the defendant had a prior opportunity to cross-examine. The reliability-based test of Ohio v. Roberts is overruled for testimonial statements. For non-testimonial hearsay, the Confrontation Clause does not apply and the statement may be admitted under applicable hearsay rules.
Significance
Crawford revolutionized Confrontation Clause doctrine by replacing the reliability-based Roberts test with a historical, categorical approach focused on whether statements are “testimonial.” It set off a wave of cases defining “testimonial” and remains the central Confrontation Clause precedent, paired in courses with Davis v. Washington and Ohio v. Clark.