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Evidence keyed to Fisher
Crawford v. Washington
Citation:
541 U.S. 36 (2004)Facts
On August 5, 1999, Kenneth Lee was stabbed at his apartment in Washington. Police arrested Michael Crawford that night and interrogated both him and his wife Sylvia after providing Miranda warnings. Crawford confessed that he and Sylvia had sought out Lee because Crawford was upset over an earlier incident in which Lee allegedly tried to rape Sylvia. During the confrontation, a fight ensued resulting in Lee being stabbed in the torso and Crawford’s hand being cut. Crawford’s statement to police suggested Lee may have been reaching for a weapon before the stabbing, though he expressed uncertainty about his recollection. Sylvia’s recorded statement to police was arguably different, particularly regarding whether Lee had drawn a weapon before Crawford assaulted him. Her statement indicated Lee reached into his pocket after being stabbed and had nothing in his hands afterward. At trial, Crawford claimed self-defense, but Sylvia did not testify due to Washington’s marital privilege. The State successfully moved to introduce Sylvia’s tape-recorded statement under the hearsay exception for statements against penal interest, arguing it was reliable and “interlocked” with Crawford’s statement.
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