Crawford v. Washington
Following is the case brief for Crawford v. Washington, United States Supreme Court, (2004)
Case summary for Crawford v. Washington:
- Mr. Crawford was charged with attempted murder of a man who allegedly attempted to rape his wife.
- Crawford’s wife made statements to the responding officers, regarding the incident.
- At trial, the prosecution tried to use the statements against Crawford, since his wife was unavailable to testify after asserting Washington’s marital privilege. Crawford argued the statement was inadmissible under the Sixth Amendment’s Confrontation Clause.
- The Court held that under the Confrontation Clause, a defendant has the right to confront witnesses who testify against him with a reasonable opportunity to cross examine and here that opportunity did not exist.
Crawford v. Washington Case Brief
Statement of the facts:
Mr. Crawford was charged with attempted murder and assault of a man who he alleged tried to rape his wife. The prosecution tried to introduce a recorded statement by Crawford’s wife where she described the stabbing. The court permitted the tape recorded statement into evidence. Crawford’s wife was unavailable to testify under the state’s marital privilege. Crawford then appealed and the Washington court of appeals held that introduction of the taped statement violated Crawford’s Sixth Amendment confrontation right.
Procedural History:
The state then appealed the decision to the state supreme court which upheld the trial court’s decision. Crawford appealed to the Supreme Court of the United States who granted certiorari.
Rule of Law or Legal Principle Applied:
Former testimony of a witness not present at trial are admissible when the declarant is unavailable and the defendant has had a previous opportunity to cross-examine the witness.
Issue and Holding:
Whether a recorded police statement made to the police is admissible at trial when made by an unavailable witness? No.
Judgment:
The Court reversed and remanded the Washington state supreme court’s judgment.
Reasoning:
- The Court held that the Sixth Amendment’s Confrontation Clause provides that a defendant has the right to confront witnesses who testify against him with a reasonable opportunity to cross examine.
The Court pointed out that the testimonial statements consist of in-court testimony and statements that the declarant reasonably expect to be used by the prosecution. Although the Confrontation Clause negates most hearsay exceptions, hearsay can be admissible if the declarant is unavailable and the defendant had a prior opportunity to cross examine the witness. The Court overturned the reliability test, previously explained in Ohio v. Roberts, 448 U.S. 56 (1980).
Although the Confrontation Clause exists to ensure that evidence is reliable, the guarantee is procedural, not substantive and cannot be compromised because the evidence is determined reliable. The Court further explains that reliability is an undefined concept which can result in judicial unreliability and admit evidence the Confrontation Clause was meant to exclude.
The Court then outlined a new standard in which testimonial statements of unavailable witnesses are admissible only where the defendant had a prior opportunity for cross examination.
Here, Crawford’s wife’s statement made against Crawford is testimonial in nature since it was made to officers in an interrogation and she knew or should have known the statement would be used as a going to be used at a following trial. Since Crawford’s wife is unavailable, due to her marital privilege, at trial in addition to the fact that Crawford did not have an opportunity to cross examine his wife’s statement, its admission would violate the Confrontation Clause.
Significance:
Crawford v. Washington established the evidentiary rule that a defendant has a right to confront witnesses who testify against them at a trial, through cross-examination.
Student Resources:
https://www.law.cornell.edu/supct/html/02-9410.ZO.html
https://supreme.justia.com/cases/federal/us/541/36/
