Michigan v. Bryant

Summary

The Supreme Court held that statements made by a mortally wounded shooting victim to police were nontestimonial under the Confrontation Clause. Applying an objective primary-purpose inquiry, the Court concluded that the questioning was intended to enable police assistance during an ongoing emergency involving an armed and unidentified shooter. The Court vacated the judgment of the Supreme Court of Michigan and remanded the case.

Holdings

1. Covington's identification and description of the shooter and the location of the shooting were not testimonial because the circumstances objectively indicated that the primary purpose of the police interrogation was to enable police assistance to meet an ongoing emergency.
2. Courts must objectively evaluate the circumstances in which the encounter occurs and the statements and actions of all parties, rather than relying on the subjective or actual purpose of any particular participant.
3. The Court did not decide whether the statements were otherwise admissible under Michigan hearsay rules and remanded that issue to the Michigan courts.

Questions Presented

1. Whether Covington's identification and description of the shooter and the location of the shooting were testimonial statements under the Sixth Amendment's Confrontation Clause.
2. Whether the admission of those statements violated Bryant's Confrontation Clause rights when Bryant had no prior opportunity to cross-examine Covington.
3. Whether the statements' admission was otherwise permissible under Michigan hearsay law.

Disposition

vacated