State v. Williams, 462 P.3d 832

Justin Williams broke down the door of his father’s motor home, assaulted his father and brother, and fled; the father called 911 shortly after the assault.
The father’s nearly nine‑minute 911 call was recorded; his tone was initially distressed and later calmer after a second dispatcher joined.
Neither the father nor the brother testified at trial; the State relied heavily on the 911 recording plus a dispatcher, a records custodian, an officer, scene photos, and birth certificates to identify parties.
Williams objected before trial that the recording was hearsay and, if testimonial, violated his Sixth Amendment Confrontation Clause right.
The district court ruled the call nontestimonial (so no Confrontation Clause problem) and admitted the recording under the excited‑utterance hearsay exception; defense counsel declined to press for redaction of later portions of the call.
The jury convicted Williams of aggravated burglary, criminal mischief, and assault; the Court of Appeals affirmed.

Issue	State's Argument	Williams's Argument	Held
Whether admitting the 911 call violated the Sixth Amendment Confrontation Clause	Call was nontestimonial because primary purpose was to obtain emergency aid during an ongoing emergency	Call was effectively testimonial and admission violated confrontation right because declarant did not testify	Court held call nontestimonial under Davis v. Washington; no Confrontation Clause violation
Whether the 911 statements were admissible under the excited‑utterance exception to hearsay	Initial, spontaneous statements were excited utterances and admissible	Later, calmer responses (descriptions, biographical details) were reflective and not excited utterances	Court held the initial portion admissible as excited utterance; later portions were not, but Williams waived challenge by abandoning his redaction request, so admission affirmed

Crawford v. Washington, 541 U.S. 36 (establishes confrontation doctrine requiring prior cross‑examination for testimonial out‑of‑court statements)
Davis v. Washington, 547 U.S. 813 (distinguishes testimonial vs. nontestimonial 911 statements; primary‑purpose test for ongoing emergency)
United States v. Olano, 507 U.S. 725 (defines waiver as intentional relinquishment of a known right)
United States v. Carrasco‑Salazar, 494 F.3d 1270 (abandoned objections constitute waiver)
United States v. Thornton, 846 F.3d 1110 (invited error described as a species of waiver)
State v. Smith, 909 P.2d 236 (Utah excited‑utterance doctrine; spontaneity requirement)
West Valley City v. Hutto, 5 P.3d 1 (factors and framework for evaluating excited utterance in Utah)