The Background of Crawford v. Washington:
Crawford v. Washington is a famous United States Supreme Court decision that ultimately reformulated the standards for determining when an admission of hearsay statements (in a criminal case) can be permitted under the Confrontation Clause—a fundamental clause of the Sixth Amendment to the United States Constitution. The Court system stated that cross-examination is mandated to admit prior testimonial statements offered by witnesses that have become unavailable for questioning.
Michael Crawford and his wife Sylvia confronted Ken Lee over an allegation that Lee had attempted to sexually abuse and rape Mrs. Crawford. During this confrontation, Michael Crawford stabbed Ken lee in the torso. After committing the assault, Crawford claimed that he had acted in self-defense, for he believed that Lee had reached for a weapon. In response, Ken Lee denied these accusations and claimed that he did not do anything to prompt Crawford into committing such an act of violence.
Both Michael and Sylvia Crawford were questioned by police upon receiving their Miranda Warning. Michael Crawford told police that was not sure if Ken lee had a weapon, but he believed at the time of the attack, that he did. Sylvia Crawford, who was interrogated separately, at first claimed that she did not see the attack, but after further questioning, she claimed that she did observe the attack and claimed that Lee was not holding a weapon nor committing any movement to suggest the presence of a weapon.
Crawford v. Washington Trial:
During trial, Sylvia Crawford could not be compelled to testify, since under Washington law of spousal privilege, a spouse is not allowed to testify in court without the defendant spouse’s consent.
The deputy prosecutor, presiding over the case, sought to introduce Sylvia Crawford’s statement to the law authorities as evidence that Mr. Crawford had no reason to believe that he was in danger when making the attack—Out-of-court statements by individuals other than the accused party are excluded as hearsay. In this situation, the court allowed the statement to be admitted on the basis that the evidence was reliable, for it was partially corroborated by Mr. Crawford’s statement to the local authorities.
The Washington Court of Appeals overturned the decision of the trial court. The court, after applying a nine-factor test to determine whether Mrs. Crawford’s statement was reliable, determined that it was not, and gave a number of reasons why.
The verdict was eventually appealed to the state’s Supreme Court, where the system reinstated the initial conviction, ruling that Mrs. Crawford’s statement was reliable. Specifically, the Washington State Supreme Court noted that the Crawford’s statements interlocked and as a result, concluded that Mrs. Crawford’s statements were admissible.
This verdict was brought to the United States Supreme Court, where it was held that the use of Mrs. Crawford’s recorded statement made during police interrogation violated the defendant’s Sixth Amendment right to be confronted with the witnesses against the individual where the spouse, as a result of the state law marital privilege, did not testify at the trial and was therefore unavailable.