Michigan v. Bryant
2011 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Michigan v. Bryant, 562 U.S. 344 (2011), was a United States Supreme Court case in which the Court further developed the "primary purpose" test to determine whether statements are "testimonial" for Confrontation Clause purposes.[1] In Bryant, the Court expanded upon the test first articulated in Davis v. Washington, "addressing for the first time circumstances in which the 'ongoing emergency' discussed in Davis extended to a potential threat to the respond police and the public at large."[1]
Michigan v. Bryant | |
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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 | |
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Case opinions | |
Majority | Sotomayor, joined by Roberts, Kennedy, Breyer, Alito |
Concurrence | Thomas (in judgment) |
Dissent | Scalia |
Dissent | Ginsburg |
Kagan took no part in the consideration or decision of the case. | |
Laws applied | |
U.S. Const. amend. VI |
The Court stated that determination of whether an interrogation's primary purpose was to assist in an "ongoing emergency" was an objective evaluation of the circumstances "in which the encounter occur[ed] and the statements and actions of the parties."[1]