Crawford v. Washington
541 U.S. 36 · Supreme Court of the United States · 2004
Facts
Michael Crawford stabbed Kenneth Lee, who allegedly tried to rape Crawford's wife, Sylvia. Crawford and Sylvia went to Lee's apartment, where a fight ensued, resulting in Lee being stabbed in the torso and Crawford's hand being cut. Police later arrested Crawford and interrogated both him and Sylvia after Miranda warnings. Crawford confessed they sought Lee due to the alleged rape attempt. Sylvia's account of the fight itself differed from Crawford's, particularly regarding whether Lee had drawn a weapon before Crawford assaulted him.
Issue
Does the admission of an unavailable witness's out-of-court, tape-recorded statement to police, without prior opportunity for cross-examination, violate the Sixth Amendment's Confrontation Clause?
Holding
Yes, the admission of Sylvia's testimonial statement without an opportunity for cross-examination violated the Sixth Amendment's Confrontation Clause. The Washington Supreme Court's judgment is reversed and the case remanded.
Rule
The Sixth Amendment's Confrontation Clause guarantees an accused the right to be confronted with the witnesses against him. This right applies to "testimonial" statements, which are formal declarations made to government officers for the purpose of establishing or proving some fact, such as statements made during police interrogations. The Clause prohibits the admission of testimonial statements from an unavailable witness unless the defendant had a prior opportunity for cross-examination. The previous *Ohio v. Roberts* "indicia of reliability" test is rejected because it improperly substitutes judicial reliability determinations for the constitutionally prescribed method of assessing reliability, which is cross-examination itself.
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