Michigan v. Bryant

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.

Michigan v. Bryant
Argued October 5, 2010
Decided February 28, 2011
Full case nameMichigan, Petitioner v. Richard Perry Bryant
Docket no.09-150
Citations562 U.S. 344 (more)
131 S. Ct. 1143; 179 L. Ed. 2d 93
ArgumentOral argument
Case history
PriorDefendant 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)
SubsequentRemanded to Michigan Supreme Court.
Holding
Dying murder victim identification and description of the shooter and of the location of the shooting were not testimonial statements, because they had a “primary purpose . . . to enable police assistance to meet an ongoing emergency.”. Their admission at trial did not violate the defendant rights under the Confrontation clause.
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajoritySotomayor, joined by Roberts, Kennedy, Breyer, Alito
ConcurrenceThomas
DissentScalia
DissentGinsburg
Kagan took no part in the consideration or decision of the case.
Laws applied
U.S. Const. amend. VI

Background

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 (2004), 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.[1]

gollark: What are you trying to calculate?
gollark: It's easier if you think about it as heads and not-heads, but heads has 1/3 probability.
gollark: Yes, because the probability of it being tails each time is independent, so multiply 1/2 by 1/2 by 1/2.
gollark: Which rolling consecutive sixes isn't.
gollark: You add probabilities for mutually exclusive events.

See also

References
  1. Michigan v. Bryant, No. 09-150, slip op. at 1 (2011).
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