Michigan v. Bryant, 131 S. Ct. 1143

Police found Covington mortally wounded in a gas station parking lot; Covington identified Rick as the shooter and described the shooting through Bryant’s back door.
Covington, bleeding and in great pain, provided initial answers to officers who asked what happened, who shot him, and where the shooting occurred.
Police questioned Covington at the scene for about 5–10 minutes before emergency services arrived; Bryant was not at home when police later searched his house.
Bryant was charged with second-degree murder, felon in possession of a firearm, and firearm during a felony; the state sought to admit Covington’s statements as non-testimonial hearsay.
Michigan Supreme Court reversed Bryant’s conviction, holding Covington’s statements were testimonial under Crawford and Davis and thus inadmissible; the court remanded.
The United States Supreme Court granted certiorari to decide whether the Confrontation Clause barred admission of Covington’s statements, and the Court held the statements were non-testimonial because they were made to meet an ongoing emergency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Covington’s police statements were testimonial.	Bryant—Covington’s statements were testimonial; Michigan court properly excluded them.	State—statements were non-testimonial under ongoing-emergency framework.	Covington’s statements were not testimonial; admission did not violate the Confrontation Clause.
What standard governs the primary purpose inquiry for testimonial vs. non-testimonial statements.	Davis’s framework suffices; ongoing emergency is central.	Court should adopt a declarant-focused approach emphasizing intent.	Court adopts objective, combined assessment of declarant and interrogator to determine primary purpose.
Is the existence of an ongoing emergency dispositive for testimonial status?	Ongoing emergency dictates non-testimonial status if present.	Ongoing emergency is one factor among several in a contextual, objective inquiry.	Ongoing emergency is a key factor but not dispositive; context and purposes of interrogation matter.
Must the inquiry look to interrogator’s motives, declarant’s motives, or both?	Interrogator’s motives determine the primary purpose.	Declarant’s perspective should drive the analysis.	A combined, objective assessment of both declarant and interrogator is required.

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial vs. non-testimonial; confrontation right requires cross-examination for testimonial statements)
Davis v. Washington, 547 U.S. 813 (U.S. 2006) (established ongoing-emergency framework; not all police questions yield testimony)
Hammon v. Indiana, 547 U.S. 813 (U.S. 2006) (emergency/ongoing threat analysis in domestic violence context)
Ohio v. Roberts, 448 U.S. 56 (U.S. 1980) (reliability-based exception to Confrontation Clause (firml rooted/particularized guarantees) prior to Crawford)
Giles v. California, 554 U.S. 353 (U.S. 2008) (limits on dying declarations; discusses confrontation in context of reliability)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (business-record-like testimonial exception; corroborates limits of hearsay without confrontation)