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 name | Michigan, Petitioner v. Richard Perry Bryant |
| Docket no. | 09-150 |
| Citations | 562 U.S. 344 (more) 131 S. Ct. 1143; 179 L. Ed. 2d 93 |
| Argument | Oral argument |
| Case history | |
| Prior | 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 | Remanded 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 | |
| |
| Case opinions | |
| Majority | Sotomayor, joined by Roberts, Kennedy, Breyer, Alito |
| Concurrence | Thomas |
| Dissent | Scalia |
| Dissent | Ginsburg |
| 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]
References
- Michigan v. Bryant, No. 09-150, slip op. at 1 (2011).
External links
- Text of Michigan v. Bryant, 562 U.S. 344 (2011) is available from: CourtListener Justia Oyez (oral argument audio) Supreme Court (slip opinion)
- Michigan v. Bryant Resource Page Containing background materials and links to key materials on the case.
- Opinion by the Michigan Supreme Court
- Michigan v. Bryant coverage on SCOTUSblog