Crawford v. Washington
| Crawford v. Washington | |
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| Argued November 10, 2003 Decided March 8, 2004 |
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| Full case name | Michael D. Crawford v. Washington |
| Citations | 541 U.S. 36 (more)
124 S. Ct. 1354; 158 L. Ed. 2d 177; 2004 U.S. LEXIS 1838; 72 U.S.L.W. 4229; 63 Fed. R. Evid. Serv. (Callaghan) 1077; 17 Fla. L. Weekly Fed. S 181
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| Prior history | Defendant convicted, Thurston County Superior Court, 11-19-99; reversed, 107 Wn. App. 1025 (2001); reversed, conviction reinstated, 54 P.3d 656 (Wash. 2002); certiorari granted, 539 U.S. 914 (2003) |
| Subsequent history | None |
| Holding | |
| The use at trial of out of court statements made to police by an unavailable witness violated a criminal defendant's Sixth Amendment right to confront witnesses against him. | |
| Court membership | |
| Case opinions | |
| Majority | Scalia, joined by Stevens, Kennedy, Souter, Thomas, Ginsburg, Breyer |
| Concurrence | Rehnquist, joined by O'Connor |
| Laws applied | |
| U.S. Const. amend. VI | |
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This case overturned a previous ruling or rulings
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| Ohio v. Roberts (1980) | |
Crawford v. Washington, 541 U.S. 36 (2004), is a United States Supreme Court decision that reformulated the standard for determining when the admission of hearsay statements in criminal cases is permitted under the Confrontation Clause of the Sixth Amendment. The Court held that cross-examination is required to admit prior testimonial statements of witnesses who have since become unavailable.
Michael Crawford and his wife Sylvia Crawford confronted Kenneth Lee over an allegation that Lee had attempted to rape Mrs. Crawford. Michael Crawford stabbed Lee in the torso. Crawford claimed he had acted in self-defense when he believed Lee had picked up a weapon. Lee denied doing anything that might make Crawford believe he was trying to attack him.
Both Mr. and Mrs. Crawford were questioned by police after receiving a Miranda warning. Mr. Crawford said to the police that he was not sure if Mr. Lee had a weapon, but that Crawford believed at the time that Lee did. Mrs. Crawford, being interrogated separately, at first said that she had not seen the attack, but under further questioning said that she had seen the attack and that Lee was not holding a weapon.
At trial, Mrs. Crawford could not be compelled to testify by the state, since under Washington's spousal privilege law, a spouse cannot testify in court without the defendant spouse's consent (except when a spouse is a complainant).
The deputy prosecutor, Robert Lund, sought to introduce Mrs. Crawford's statement to the police as evidence that Mr. Crawford had no reasonable belief that he was in danger from Mr. Lee. Generally, out-of-court statements by persons other than the accused are excluded as hearsay. Here the court allowed the statement to be admitted on the basis that the statement was reliable, as it was partially corroborated by Mr. Crawford's statement to police.
Defense counsel objected to the admission of the wife's statement, on the ground that Mr. Crawford would be unable to confront (i.e. cross-examine) Mrs. Crawford on her statement without waiving spousal privilege, and that this would be a violation of the Confrontation Clause of the Sixth Amendment.
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