541 U.S. 36 (2004)
On August 5, 1999, Michael Crawford stabbed Kenneth Lee in the torso during a confrontation at Lee's apartment.1
Crawford and his wife Sylvia had gone there after Sylvia alleged that Lee had attempted to rape her several weeks earlier.2 Lee was taken to the hospital and later died from his wounds.3 Police arrested both Crawford and Sylvia that night.4
Detectives gave Miranda warnings and interrogated Sylvia twice at the station house.5 In her recorded statement Sylvia initially denied involvement but eventually admitted she had led Crawford to Lee's apartment and had seen the stabbing.6 Crawford also gave police a statement describing the events and his belief that Lee may have reached for something before the stabbing.7 At trial Crawford asserted self-defense, but Sylvia did not testify because of Washington's marital privilege.8
The State offered Sylvia's tape-recorded statement as evidence that the stabbing was not in self-defense and invoked the hearsay exception for statements against penal interest.9 The trial court admitted the statement after finding it bore particularized guarantees of trustworthiness.10 The jury convicted Crawford of assault.11 The Washington Court of Appeals reversed after applying a nine-factor test and concluding the statement lacked sufficient indicia of reliability.12
The Washington Supreme Court reinstated the conviction.13 It determined that Sylvia's statement interlocked with Crawford's statement and therefore bore adequate guarantees of trustworthiness, noting that both accounts were ambiguous on whether Lee had possessed a weapon.14 The United States Supreme Court granted certiorari.15
Whether the Confrontation Clause permits the admission against a criminal defendant of a testimonial statement made by an unavailable witness when the defendant had no prior opportunity for cross-examination?16
The Confrontation Clause requires unavailability and a prior opportunity for cross-examination before testimonial statements of an absent witness may be admitted against a criminal defendant.17
No. Sylvia Crawford's recorded statement was made during structured police interrogation after Miranda warnings and was offered to disprove self-defense.18 She did not testify at trial due to marital privilege, leaving Crawford without any opportunity for cross-examination.19 The Washington Supreme Court admitted the statement based on interlocking with Crawford's account and other reliability factors, but the Clause demands confrontation for testimonial statements rather than judicial reliability assessments.20
Admission of Sylvia Crawford's statement violated the Confrontation Clause.21
Related opinions on this issue
Joined by O’connor, J.
Chief Justice Rehnquist, joined by Justice O’Connor, dissented from the decision to overrule Ohio v. Roberts.22 He contended that the Roberts test had served the criminal justice system well for more than two decades.23 It provided a flexible framework that allows courts to balance the interests of the defendant in confronting adverse witnesses with the State’s interest in presenting reliable evidence.24
Rehnquist argued that the Court’s new rule excluding virtually all testimonial hearsay is not supported by the text or history of the Confrontation Clause.25 He maintained that the Clause permits the admission of hearsay statements that bear sufficient indicia of reliability.26 He would have affirm the judgment of the Washington Supreme Court because Sylvia Crawford’s statement bore sufficient indicia of trustworthiness as it was made shortly after the events, in a noncustodial setting, without apparent motive to lie, and was corroborated by other evidence.
Whether a statement knowingly given by a witness to police officers during a structured custodial interrogation qualifies as a testimonial statement under the Confrontation Clause?27
Statements knowingly given in response to structured police questioning qualify as testimonial under the Confrontation Clause.28
Yes. Sylvia Crawford was given Miranda warnings and responded to structured questioning by detectives at the station house.29 She ultimately admitted leading Crawford to the apartment and witnessing the stabbing.30 Such a statement, knowingly provided during formal police interrogation, falls within the core class of testimonial statements the Clause targets.31
Sylvia Crawford's statement is testimonial.32
Whether the reliability framework of Ohio v. Roberts governs the admissibility of testimonial hearsay under the Confrontation Clause?33
The Roberts framework of firmly rooted exceptions or particularized guarantees of trustworthiness does not govern admissibility of testimonial hearsay; the Clause instead requires a prior opportunity for cross-examination.34
No. The Washington Supreme Court relied on the interlocking character of the statements and other reliability factors drawn from Roberts to admit Sylvia Crawford's statement.35 For testimonial statements, however, the Clause prescribes confrontation rather than judicial weighing of reliability indicia, rendering the Roberts test inapplicable.36
The Roberts framework does not govern the admissibility of testimonial hearsay.37
Related opinions on this issue
Joined by O’connor, J.
Chief Justice Rehnquist, joined by Justice O’Connor, dissented from the decision to overrule Ohio v. Roberts. He contended that the Roberts test had served the criminal justice system well for more than two decades. It provided a flexible framework that allows courts to balance the interests of the defendant in confronting adverse witnesses with the State’s interest in presenting reliable evidence.
Rehnquist argued that the Court’s new rule excluding virtually all testimonial hearsay is not supported by the text or history of the Confrontation Clause. He maintained that the Clause permits the admission of hearsay statements that bear sufficient indicia of reliability. He would have affirm the judgment of the Washington Supreme Court because Sylvia Crawford’s statement bore sufficient indicia of trustworthiness as it was made shortly after the events, in a noncustodial setting, without apparent motive to lie, and was corroborated by other evidence.