Ohio v. Clark
E822925
Ohio v. Clark is a 2015 U.S. Supreme Court decision that clarified the limits of the Confrontation Clause in the context of statements made by child abuse victims to non-law-enforcement individuals.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Ohio v. Clark canonical | 1 |
Statements (48)
| Predicate | Object |
|---|---|
| instanceOf |
Confrontation Clause case
ⓘ
United States Supreme Court case ⓘ criminal procedure case ⓘ |
| appliedPrecedent |
Crawford v. Washington
NERFINISHED
ⓘ
Davis v. Washington NERFINISHED ⓘ Michigan v. Bryant NERFINISHED ⓘ |
| areaOfLaw |
constitutional criminal procedure
ⓘ
evidence law ⓘ |
| citation | 576 U.S. 237 ⓘ |
| citationStyle | Ohio v. Clark, 576 U.S. 237 (2015) NERFINISHED ⓘ |
| constitutionalProvisionInterpreted | Sixth Amendment to the United States Constitution NERFINISHED ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 2015-06-18 ⓘ |
| docketNumber | 13-1352 ⓘ |
| factsSummary | A three-year-old child with visible injuries identified his mother’s boyfriend, Darius Clark, as the abuser when questioned by preschool teachers. ⓘ |
| fullName | Ohio v. Clark NERFINISHED ⓘ |
| holding | Statements made by a child to his teachers about suspected abuse were not testimonial and their admission at trial did not violate the Confrontation Clause. ⓘ |
| impact |
clarified that statements by very young children to teachers about abuse can be admitted without violating the Confrontation Clause when not primarily intended as testimony.
ⓘ
narrowed the circumstances in which out-of-court statements are considered testimonial. ⓘ |
| joinedByInMajority |
Anthony M. Kennedy
NERFINISHED
ⓘ
Antonin Scalia NERFINISHED ⓘ Clarence Thomas NERFINISHED ⓘ Elena Kagan NERFINISHED ⓘ John G. Roberts Jr. NERFINISHED ⓘ Ruth Bader Ginsburg NERFINISHED ⓘ Sonia Sotomayor NERFINISHED ⓘ Stephen G. Breyer NERFINISHED ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| legalIssue |
scope of the Sixth Amendment Confrontation Clause
ⓘ
statements by child abuse victims to non-law-enforcement personnel ⓘ testimonial versus nontestimonial hearsay ⓘ |
| majorityOpinionBy | Samuel A. Alito Jr. NERFINISHED ⓘ |
| originatingJurisdiction | State of Ohio NERFINISHED ⓘ |
| petitioner | State of Ohio NERFINISHED ⓘ |
| proceduralHistory | Ohio courts held that admission of the child’s statements to teachers violated the Confrontation Clause. ⓘ |
| relatedTo |
child protective reporting statutes
ⓘ
mandatory reporter obligations of teachers ⓘ |
| respondent | Darius Clark NERFINISHED ⓘ |
| resultForRespondent | conviction reinstated ⓘ |
| reversed | judgment of the Supreme Court of Ohio ⓘ |
| ruleOfLaw |
Mandatory reporting duties of teachers do not by themselves transform conversations with students into law-enforcement interrogations.
ⓘ
Statements are testimonial when their primary purpose is to create an out-of-court substitute for trial testimony. ⓘ Statements to individuals who are not law enforcement officers are less likely to be testimonial. ⓘ |
| subjectMatter |
child abuse
ⓘ
criminal prosecution for assault and related offenses ⓘ hearsay evidence ⓘ |
| term | October Term 2014 ⓘ |
| vote | 9-0 ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.