Document Type

Article

Publication Title

University of Pennsylvania Law Review

Publication Date

12-2012

ISSN

0006-8047

Page Number

1865

Keywords

Davis v. Washington, testimonial statements, evidence, Confrontation Clause

Disciplines

Evidence | Jurisprudence | Law

Abstract

Sharp turns in the Supreme Court's recent Confrontation Clause jurisprudence have left scholars reeling from conflicting emotions: exhilaration, despair, denial, and soon, perhaps, cynical acceptance. While most commentators celebrated the demise of the incoherent Ohio v. Roberts framework, their excitement largely faded as the Court's decisions in Davis v. Washington and Bryant v. Michigan revealed nascent flaws in the evolving doctrine and sharply curtailed the newly revitalized confrontation right.

Recent scholarship strives to reanimate the jurisprudence by expanding the doctrinal definition of "testimonial" statements - the sole form of evidence Associate Professor, William & Mary Law School. I would like to thank Jeffrey Fisher, Richard Friedman, and Josephine Ross for their comments on an earlier draft of this Article. Donna Bowman, Rachel Castillo, and Brandon Horowitz contributed valuable research assistance. This Article would not have been possible without the patience and support of Catherine Zoe Garrett.

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