Jackson v. State, 291 Ga. 22

On Nov. 14, 1998, Jackson spent time at Formosa Bell's home; he then went to a nearby party with Frazier, both carrying guns.
At the party, Frazier returned his gun to Jackson; Tucker, a party host, told them not to bring guns inside.
An argument with Tucker escalated; Jackson opened fire, fatally shooting Tucker multiple times.
Bell testified that she witnessed Jackson argue with Tucker and that Jackson became highly agitated; Jackson admitted shooting in a taped statement.
Frazier died before trial; his police statement was admitted under the necessity exception to the hearsay rule.
The trial court admitted Frazier’s statement; Jackson argued it violated Crawford v. Washington; the Court later deemed the error harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Frazier's testimonial statement violated Crawford	Frazier's statement was testimonial and unlawful to admit without confrontation.	State concedes the statement was testimonial and improperly admitted; however, the error is harmless.	Crawford violation occurred but was harmless.
Whether the Crawford error affected the conviction	Harsh prejudice from admission of the testimonial statement taints the verdict.	Error was harmless due to cumulative and corroborating evidence.	Harmless error; evidence sufficient to sustain the verdict.

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimony and confrontation clause control admissibility)
Bell v. State, 278 Ga. 69, 597 S.E.2d 350 (Ga. 2004) (investigative statements deemed testimonial under Crawford)
Moody v. State, 277 Ga. 676, 594 S.E.2d 350 (Ga. 2004) (reaffirms Crawford-related evidence rules)
Watson v. State, 278 Ga. 763, 604 S.E.2d 804 (Ga. 2004) (statements to police during investigation testimonial)
Gay v. State, 279 Ga. 180, 611 S.E.2d 31 (Ga. 2005) (Crawford violation analyzed for harmless error)