Michigan v. Bryant

Michigan v. Bryant, 562 U.S. ___ (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.

Background

Detroit police 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.

External links

• Michigan v. Bryant Resource Page Containing background materials and links to key materials on the case.
• Slip opinion from the Supreme Court
• Opinion by the Michigan Supreme Court
• Michigan v. Bryant coverage on SCOTUSblog