Thursday, December 5, 2013

Michigan v. Bryant case brief

Michigan v. Bryant case brief summary
131 S. Ct. 1143 (2010)


CASE SYNOPSIS
Criminal defendant was found guilty of, inter alia, second-degree murder. The Michigan Supreme Court reversed his conviction, holding that the Sixth Amendment's Confrontation Clause rendered a mortally wounded shooting victim's statements inadmissible testimonial hearsay. Petitioner State of Michigan's petition for a writ of certiorari was granted as to whether the Confrontation Clause barred admission of the victim's statements.

CASE FACTS
Police dispatched to a gas station parking lot found the victim mortally wounded. He told them that he had been shot by defendant outside defendant's house and had then driven himself to the lot. The officers testified at trial about what the victim had told them. The victim was unavailable at trial because he had died shortly after the shooting. What the victim told the officers was that he fled the shooter's back porch, indicating that he perceived an ongoing threat. The police did not know, and the victim did not tell them, whether the threat was limited to him. The informality of the exchange suggested that the officers' purpose was to address what they perceived to be an ongoing emergency. The circumstances lacked any formality that would have alerted the victim to or focused him on the possible future prosecutorial use of his statements.

DISCUSSION

  • Because of these circumstances, the victim's identification and description of the shooter and the location of the shooting were not testimonial hearsay. 
  • The Confrontation Clause did not bar their admission at defendant's trial.

CONCLUSION
The judgment of the Supreme Court of Michigan was vacated, and the case was remanded for further proceedings not inconsistent with the opinion. It was left to the Michigan courts to decide on remand whether the statements' admission was otherwise permitted by state hearsay rules. 6-2 Decision; one concurrence in the judgment, two dissents.

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