The State introduced Sylvia Crawford's recorded statement against petitioner in a criminal prosecution. She gave the statement while in police custody in response to structured police questioning, and the statement implicated her husband in the stabbing and at least arguably undermined his self-defense claim. Petitioner had no opportunity to cross-examine Sylvia. The State nevertheless used the statement at trial.
Issue
Whether the Confrontation Clause permits the State to introduce a witness's out-of-court testimonial statement made during police interrogation when the witness does not appear at trial and the defendant had no prior opportunity to cross-examine the witness.
Rule
Where testimonial evidence is at issue, the Sixth Amendment demands what the common law required: the declarant must be unavailable and the defendant must have had a prior opportunity for cross-examination. Testimonial statements include, at a minimum, prior testimony at a preliminary hearing, before a grand jury, or at a former trial, and statements taken by police officers in the course of interrogations. Reliability determined by a judge under Ohio v. Roberts is not a sufficient substitute for confrontation.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, Mateo Ruiz is tried for armed robbery. The prosecution offers a recorded station-house interview of Nina Cole, who answered structured questions from detectives and identified Mateo as the driver; Nina has moved overseas and does not appear at trial, and Mateo never had any chance to question her.
Should the recording be excluded under the Sixth Amendment?
Explanation. The majority held that statements taken by police officers in the course of interrogations are testimonial at a minimum. When testimonial evidence is offered against a criminal defendant, the Sixth Amendment requires unavailability and a prior opportunity for cross-examination. Judicial findings of trustworthiness are not a substitute. Here, although Nina is absent, Mateo never had a prior opportunity to cross-examine her, so the recording must be excluded.