Dying Declarations Exception to Crawford
Michigan v. Bryant (2011)
The Dying Declarations Exception to Crawford, illustrated in Michigan v. Bryant (2011), is a significant aspect of the Sixth Amendment’s Confrontation Clause.
1. Recognition of Exception: Michigan v. Bryant dealt with the admissibility of a shooting victim’s statements to police officers before his death. The Supreme Court ruled that these statements fell under the dying declaration exception to the Confrontation Clause. This exception allows statements made by a person who believes they are facing imminent death, primarily to describe the cause or circumstances of their impending death, to be admitted in court.
2. Justifications for Exception: The Court reasoned that dying declarations are inherently trustworthy because they’re made under the belief of impending death, reducing the likelihood of falsehoods. Additionally, the primary motive behind such statements is to record relevant information about the circumstances leading to the declarant’s death, rather than to accuse someone. Thus, admitting dying declarations serves the interest of justice by allowing the victim’s final testimony to be heard.
3. Limitations and Safeguards: Despite recognizing the exception, the Court stressed the importance of ensuring the reliability of such statements. It noted that circumstances like the declarant’s perception of their impending death and the purpose of their statement must be carefully assessed. Moreover, safeguards are necessary to prevent abuses, such as ensuring statements are made in response to structured police questioning rather than spontaneous or leading interrogation.
4. Confrontation Clause Concerns: While dying declarations are an exception to the Confrontation Clause, Michigan v. Bryant acknowledged potential concerns about the defendant’s ability to cross-examine the declarant. However, the Court concluded that the reliability and necessity of dying declarations for justice outweighed these concerns, given the circumstances surrounding statements made under the belief of imminent death.