Facts of the case
Michael Crawford stabbed a man he claimed tried to rape his wife. During Crawford’s trial, prosecutors played for the jury his wife’s tape-recorded statement to the police describing the stabbing. The statement contradicted Crawford’s argument that he stabbed the man in defense of his wife. Because it was pre-recorded, Crawford could not cross-examine the statement. The jury convicted Crawford for assault.Crawford claimed the playing of his wife’s statement, with no chance for cross-examination, violated the Sixth Amendment guarantee that [i]n all criminal prosecutions, the accused shall enjoy the right…to be confronted with the witnesses against him.The state supreme court upheld the conviction, relying on the U.S. Supreme Court’s decision in Ohio v. Roberts (1980). That decision allowed the admission of out-of-court testimony against a defendant if that testimony was reliable.
Why is the case important?
The Petitioner, Crawford (the “Petitioner”), brought this action after he was convicted of stabbing a man who tried to rape his wife, when the prosecution was allowed to present her recorded statement against him.
Whether an out of court statement can be used against a defendant to assert the truth of the matter at issue?
Yes. After examine the history behind the Confrontation Clause, the Supreme Court arrived at two conclusions about it. “First, the principal evil at which the Confrontation Clause was directed was the civil-law mode of criminal procedure, and particularly its use of ex parte examinations as evidence against the accused.” Based on this, the Court rejected “the view that the Confrontation Clause applies of its own force only to in-court testimony, and that its application to out-of-court statements introduced at trial depends upon “the law of Evidence for the time being.”
Second, “that the Framers would not have allowed admission of testimonial statements of a witness who did not appear at trial unless he was unavailable to testify, and the defendant had had a prior opportunity for cross-examination.”
It concluded that “[i]n this case, the State admitted Sylvia’s testimonial statement against petitioner, despite the fact that he had no opportunity to cross-examine her. That alone is sufficient to make out a violation of the Sixth Amendment.” In so doing, it overruled Ohio v. Roberts, which “conditioned the admissibility of all hearsay evidence on whether it falls under a ‘firmly rooted hearsay exception’ or bears ‘particularized guarantees of trustworthiness.’”
Concurrence. Justice Rehnquist, joined by Justice O’Connor, disagreed with the Court’s decision to overturn Roberts.
The state asserted that the United States Supreme Court precedent allowed the use of the wife’s statement, which arguably controverted defendant’s assertion of self-defense, since the wife was unavailable as a trial witness due to marital privilege and her statement to an interrogating police officer had sufficient reliability. The Supreme Court held, however, that the prior case law erroneously permitted admission of the wife’s statement based on the amorphous concept of reliability without taking into account the constitutional requirement of confrontation that the statement be subject to cross-examination. The wife’s statement during interrogation was testimonial in nature, rather than non-testimonial hearsay which would be properly subject to evidentiary rules concerning reliability, and defendant’s right to confront the wife thus clearly included the right to cross-examine the statement, especially in view of the ambiguity in the statement. The right to confrontation was not a substantive guarantee that evidence be reliable, but rather a procedural guarantee that the reliability of the wife’s statement be tested by cross-examination.
- Advocates: Steven C. Sherman argued the cause for Respondent Jeffrey L. Fisher argued the cause for Petitioner Michael R. Dreeben argued the cause for Petitioner, on behalf of the United States, as amicus curiae Deputy Solicitor General Dreeben argued the cause for the United States as amicus curiae urging affirmance
- Petitioner: Michael D. Crawford
- Respondent: Washington
- DECIDED BY:Rehnquist Court
- Location: –
|Citation:||541 US 36 (2004)|
|Granted:||Jun 9, 2003|
|Argued:||Nov 10, 2003|
|Decided:||Mar 8, 2004|