Michigan v. Bryant
|Michigan v. Bryant|
|Argued October 5, 2010|
Decided February 28, 2011
|Full case name||Michigan, Petitioner v. Richard Perry Bryant|
|Citations||562 U.S. 344 (more)|
|Prior history||Defendant convicted at trial; affirmed, case n°247039, 2004 WL 1882661 (Mich. Ct. App., 2004); vacated and remanded in light of Davis v. Washington, 477 Mich. 902, 722 N.W.2d 797 (2006); affirmed anew, case n°247039, 2007 WL 675471 (Mich. Ct. App., 2006); reversed, 483 Mich. 132, 768 N.W.2d 65 (2009)|
|Subsequent history||Remanded to Michigan Supreme Court.|
|The statement was not testimonial and thus its admission did not violate the Confrontation Clause.|
|Majority||Sotomayor, joined by Roberts, Kennedy, Breyer, Alito|
|Kagan took no part in the consideration or decision of the case.|
|U.S. Const. amend. VI|
Michigan v. Bryant, 562 U.S. 344 (2011), was a United States Supreme Court case in which the Court considered a criminal defendant's Confrontation Clause right regarding statements made by a deceased declarant.
Detroit Police Department officers were dispatched to a gas station parking lot, and found Anthony Covington wounded. Covington told them that he had been shot by Bryant outside Bryant's house. At trial, the officers testified about what Covington said. Bryant was found guilty of murder. The testimony of the officers was challenged as a testimonial hearsay. Ultimately, the Michigan Supreme Court reversed his conviction, holding that the Sixth Amendment's Confrontation Clause, as explained in Crawford v. Washington, rendered Covington's statements inadmissible testimonial hearsay.
Opinion of the Court
The United States Supreme Court reversed the Michigan Supreme Court's ruling, and held that the victim's statements were not testimonial and that they were properly admitted at trial. The test the court used was the primary purpose test. That test draws a distinction between statements made to the authorities that are aimed at gathering facts for the purpose of prosecution versus statements made because there is an ongoing emergency.