California
How Crawford v. Washington applies in California: state-specific rules, key cases, and bar exam notes for Criminal Procedure.
California adheres to the core principles established in Crawford v. Washington, particularly regarding the confrontation clause and the admissibility of hearsay. The California Supreme Court has applied the case's foundational idea, focusing on the necessity for defendants to confront witnesses against them directly.
Under California Evidence Code § 1200 and its constitutional provisions, statements that qualify as hearsay cannot be admitted unless they meet an exception, and in cases involving testimonial statements, defendants have the right to confront their declarants.
Held that autopsy reports constituted testimonial statements, and admitting them without allowing defendant to confront the medical examiner was a violation of the Confrontation Clause.
Established that statements made to police during an ongoing emergency may not be considered testimonial, thus allowing their admission without violating Crawford.
Reiterated that witnessing testimonial hearsay requires confrontation; failing to do so can result in a retrial.
California's application of the Confrontation Clause closely mirrors the federal standard established in Crawford v. Washington. However, California has further clarified the distinction between testimonial and non-testimonial statements through its own case law, providing additional guidance on admissibility that may vary from federal interpretations.
Crawford v. Washington principles are frequently tested on the California bar exam, particularly concerning evidentiary rules around hearsay and the right to confrontation.