Michigan v. Bryant
E821198
Michigan v. Bryant is a 2011 U.S. Supreme Court decision that further defined the scope of the Confrontation Clause by clarifying when statements made to police are considered “testimonial” and thus subject to Sixth Amendment protections.
Statements (51)
| Predicate | Object |
|---|---|
| instanceOf |
Confrontation Clause case
ⓘ
United States Supreme Court case ⓘ criminal procedure case ⓘ |
| areaOfLaw |
constitutional law
ⓘ
criminal law ⓘ evidence law ⓘ |
| citation | 562 U.S. 344 ⓘ |
| concurrenceBy | Justice Antonin Scalia NERFINISHED ⓘ |
| constitutionalProvisionInterpreted | U.S. Constitution, Amendment VI NERFINISHED ⓘ |
| court | Supreme Court of the United States ⓘ |
| criminalChargeContext | murder prosecution ⓘ |
| decisionDate | 2011-02-28 ⓘ |
| dissentBy |
Justice Antonin Scalia
NERFINISHED
ⓘ
Justice Elena Kagan NERFINISHED ⓘ Justice Ruth Bader Ginsburg NERFINISHED ⓘ |
| dissentJoinedBy | Justice Sonia Sotomayor (in part) NERFINISHED ⓘ |
| docketNumber | 09-150 ⓘ |
| factPattern |
Police questioned a gunshot victim at a gas station about who shot him and where the shooting occurred.
ⓘ
The victim identified Richard Bryant as the shooter before dying. ⓘ |
| holding |
Statements made to police are nontestimonial when the primary purpose of the interrogation is to enable police assistance to meet an ongoing emergency.
ⓘ
The existence and scope of an ongoing emergency is a highly context-dependent inquiry. ⓘ The victim’s statements to police identifying the shooter and describing the shooting were admissible as nontestimonial under the Confrontation Clause. ⓘ When the primary purpose of an interrogation is to establish or prove past events potentially relevant to later criminal prosecution, the statements are testimonial. ⓘ |
| impact |
Expanded the scope of nontestimonial statements in the context of ongoing emergencies.
ⓘ
Further refined the definition of testimonial statements after Crawford v. Washington. ⓘ |
| issue | Whether a mortally wounded victim’s statements to police about the identity of his shooter were testimonial under the Confrontation Clause. ⓘ |
| joinedMajorityBy |
Chief Justice John G. Roberts, Jr.
NERFINISHED
ⓘ
Justice Anthony M. Kennedy NERFINISHED ⓘ Justice Clarence Thomas NERFINISHED ⓘ Justice Samuel A. Alito, Jr. NERFINISHED ⓘ Justice Stephen G. Breyer NERFINISHED ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| legalSubject |
Confrontation Clause
NERFINISHED
ⓘ
Sixth Amendment NERFINISHED ⓘ criminal evidence ⓘ |
| majorityOpinionBy | Justice Sonia Sotomayor NERFINISHED ⓘ |
| originatingCourt | Michigan state courts NERFINISHED ⓘ |
| petitioner | State of Michigan NERFINISHED ⓘ |
| proceduralPosture | Review of a Michigan Supreme Court decision that had excluded the victim’s statements as testimonial. ⓘ |
| relatedCase |
Bullcoming v. New Mexico
NERFINISHED
ⓘ
Crawford v. Washington NERFINISHED ⓘ Davis v. Washington NERFINISHED ⓘ Hammon v. Indiana NERFINISHED ⓘ Melendez-Diaz v. Massachusetts NERFINISHED ⓘ Ohio v. Roberts NERFINISHED ⓘ |
| respondent | Richard Bryant NERFINISHED ⓘ |
| result | Judgment of the Michigan Supreme Court reversed and case remanded. ⓘ |
| standardAnnounced | Primary purpose test for determining whether statements are testimonial under the Confrontation Clause. ⓘ |
| standardClarified | Objective evaluation of the circumstances and the statements and actions of both the declarant and the interrogators. ⓘ |
| stateInvolved | Michigan NERFINISHED ⓘ |
| term | October Term 2010 ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.