Wednesday, December 18, 2013

Davis v. Washington case brief


Davis v. Washington case brief summary
547 U.S. 813 (2006)

CASE SYNOPSIS
On writ of certiorari to the Supreme Court of Washington, defendant challenged his conviction, arguing that testimony by a 911 operator about a caller identifying him as her assailant was inadmissible hearsay. On writ of certiorari to the Supreme Court of Indiana, defendant challenged his conviction, arguing that a police officer's testimony about statements made by the alleged victim at the crime scene was inadmissible hearsay.

DISCUSSION

  • The two cases required a determination of when statements made to law enforcement personnel during a 911 call or at a crime scene were "testimonial" and thus subject to the requirements of the Sixth Amendment's Confrontation Clause. 
  • The statement identifying defendant during the 911 call was not "testimonial." A 911 call was not designed to establish or prove past facts, but to describe circumstances requiring police assistance. The caller spoke about events as they were actually occurring while facing an ongoing emergency, rather than describing past events. 
  • The elicited statements were necessary to resolve the emergency rather than to investigate events. In the other case, the statements of the alleged victim were made in response to an officer's questions in a room away from defendant when there was no immediate threat to her person. 
  • The purpose of the interrogation was investigatory. 
  • The statements recounted past events; they did precisely what a witness did on direct examination and were inherently "testimonial." 
  • The Court declined to relax the requirements in domestic violence cases but pointed out that the right to confrontation could be forfeited by wrongdoing.
CONCLUSION
The Court affirmed the judgment of the Supreme Court of Washington. The Court reversed the judgment of the Supreme Court of Indiana and remanded the case for proceedings not inconsistent with the Court's opinion.

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