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.

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Label Occurrences
Michigan v. Bryant canonical 2

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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
linked to: Antonin Scalia
constitutionalProvisionInterpreted U.S. Constitution, Amendment VI
court Supreme Court of the United States
criminalChargeContext murder prosecution
decisionDate 2011-02-28
dissentBy Justice Antonin Scalia
linked to: Antonin Scalia

Justice Elena Kagan
linked to: Elena Kagan

Justice Ruth Bader Ginsburg
linked to: Ruth Bader Ginsburg
dissentJoinedBy Justice Sonia Sotomayor (in part)
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.
linked to: John G. Roberts Jr.

Justice Anthony M. Kennedy
linked to: Anthony M. Kennedy

Justice Clarence Thomas
linked to: Clarence Thomas

Justice Samuel A. Alito, Jr.
linked to: Samuel A. Alito Jr.

Justice Stephen G. Breyer
linked to: Stephen G. Breyer
jurisdiction United States
legalSubject Confrontation Clause
Sixth Amendment
criminal evidence
majorityOpinionBy Justice Sonia Sotomayor
linked to: Sonia Sotomayor
originatingCourt Michigan state courts
petitioner State of Michigan
linked to: Michigan
proceduralPosture Review of a Michigan Supreme Court decision that had excluded the victim’s statements as testimonial.
relatedCase Bullcoming v. New Mexico
Crawford v. Washington
Davis v. Washington
Hammon v. Indiana
Melendez-Diaz v. Massachusetts
Ohio v. Roberts
respondent Richard Bryant
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
term October Term 2010

How these facts were elicited

Referenced by (2)

Full triples — surface form annotated when it differs from this entity's canonical label.

Ohio v. Clark appliedPrecedent Michigan v. Bryant