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Criminal Procedure Keyed to Dressler
Michigan v. Bryant
Citation:562 U.S. 344, 131 S.Ct. 1143, 179 L.Ed.2d 93.
Around 3:25 a.m. on April 29, 2001, police officers responded to a call indicating that a man had been shot. They found the victim, Anthony Covington, lying on the ground next to his car in a gas station parking lot with a gunshot wound. The police asked him what had happened, who had shot him, and where the shooting had occurred. The victim stated that “Rick” shot him at around 3 a.m. He also indicated that he had a conversation with the defendant, whom he recognized based on his voice, through the back door of the defendant’s house. The victim explained that when he turned to leave, he was shot through the door and then drove to the gas station, where police found him. The victim died shortly after.
At the defendant’s trial, the court admitted the statements that the victim made to police officers. The defendant was convicted of murder. On appeal, the Supreme Court of Michigan reversed and held that the Sixth Amendment’s Confrontation Clause rendered Covington’s statements inadmissible as they were testimonial statements.
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