Davis v. Washington, 547 U.S. 813 (2006)
Primary Holding
Statements made to law enforcement during a 911 call are considered "testimonial" and thus subject to the Sixth Amendment's Confrontation Clause when they are made with the primary purpose of establishing or proving past events potentially relevant to a criminal prosecution.
In the case of Davis v. Washington, a woman called 911 during a domestic violence incident and provided details about her attacker. The Supreme Court ruled that statements made during such emergency calls can be used in court because they are considered important for understanding what happened. This ruling helps protect consumers by ensuring that victims can report crimes without worrying that their statements will be ignored later in court, especially when they are in immediate danger. This case is relevant if someone is involved in a situation where they report a crime or emergency, as it reinforces their right to have their statements taken seriously in legal proceedings.
AI-generated plain-language summary to help you understand this case
In Davis v. Washington, the underlying events began on February 1, 2001, when Michelle McCottry made a 911 call reporting a domestic disturbance involving her former boyfriend, Adrian Martell Davis. During the call, McCottry informed the 911 operator that Davis was physically assaulting her, stating, "He’s here jumpin’ on me again." The operator gathered critical information about Davis, including his name and the nature of the assault, while assuring McCottry that help was on the way. The police arrived within four minutes of the call and observed McCottry in a distressed state with visible injuries. The procedural history of the case involved the State of Washington charging Davis with felony violation of a domestic no-contact order based on the incident. The only witnesses for the State were the two police officers who responded to the 911 call. They testified that McCottry had recent injuries but could not confirm the cause of those injuries, as they did not witness the assault themselves. The case ultimately reached the Supreme Court of the United States through a writ of certiorari, where the Court was tasked with determining whether the statements made by McCottry during the 911 call were "testimonial" and thus subject to the Sixth Amendment's Confrontation Clause. The relevant background context includes the legal implications of statements made during emergency calls and how they relate to a defendant's right to confront witnesses against them. The case raised significant questions about the nature of testimonial evidence in the context of domestic violence incidents and the role of emergency operators in collecting information during such calls. The outcome of this case would have implications for how similar cases are handled in the future, particularly regarding the admissibility of statements made in emergency situations.
Whether statements made to law enforcement personnel during a 911 call or at a crime scene are considered "testimonial" and thus subject to the requirements of the Sixth Amendment's Confrontation Clause.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- March 20, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Dixon v. United States, 548 U.S. 1 (2006)
Consumer LostThe burden of proof for a defense of duress in a criminal trial lies with the defendant to establish the defense by a preponderance of the evidence, rather than requiring the government to disprove the defense beyond a reasonable doubt.
Brigham City v. Stuart, 547 U.S. 398 (2006)
Consumer LostPolice may enter a home without a warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury, as established by the emergency aid doctrine.
Washington v. Recuenco, 548 U.S. 212 (2006)
Consumer LostA violation of the Sixth Amendment right to a jury trial, as established in Blakely v. Washington, is not subject to a harmless error analysis; thus, any such violation requires the vacating of the sentence.
Youngblood v. West Virginia, 547 U.S. 867 (2006)
Mixed OutcomeThe suppression of evidence favorable to the defense, as established in Brady v. Maryland, constitutes a violation of the defendant's constitutional rights, and such evidence must be disclosed to ensure a fair trial.