Langley v. State, 28 A.3d 646

Langley was convicted of first-degree murder, use of a handgun in a crime of violence, and wearing or carrying a handgun.
A 9-1-1 recording describing the shooter and vehicle was admitted over defense objection.
Witness testimony linked Langley to the crime scene via a getaway vehicle and firearm evidence.
The 9-1-1 call included the caller describing tag number, car color, and clothing, labeled by the trial court as an excited utterance.
The intermediate appellate court held the 9-1-1 statements were non-testimonial and admissible under Crawford/Davis analysis.
Petition for certiorari challenged Confrontation Clause implications and harmless-error analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 9-1-1 recording violated the Confrontation Clause	Langley argues the caller's absence precludes confrontation.	State contends statements are non-testimonial excited utterance admissible without cross-examination.	Non-testimonial; no Confrontation Clause violation
Whether the admission of the 9-1-1 recording was harmless beyond a reasonable doubt	Langley contends error; defense failure to cross-examine prejudicial.	State asserts any error was harmless given ample other evidence.	Issue unnecessary to disturb; majority affirms admission on non-testimonial basis

Crawford v. Washington, 541 U.S. 36 (U.S. Supreme Court, 2004) (testimonial vs. non-testimonial framework)
Davis v. Washington, 547 U.S. 813 (U.S. Supreme Court, 2006) (primary purpose test for ongoing emergency)
Michigan v. Bryant, 131 S. Ct. 1143 (U.S. Supreme Court, 2011) (context-dependent ongoing-emergency analysis clarified)
State v. Lucas, 407 Md. 307 (Md. 2009) ( Maryland test applying Davis/Bryant criteria to 911 calls)
Beatrice, 460 Mass. 255 (Mass. 2011) (emergency threat analysis in 911-call context)