Michigan v. Bryant

131 S.Ct. 1143 (2011)

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Nature of the Case

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Facts

Police found Covington lying on the ground next to his car in a gas station parking lot. Covington had a gunshot wound to his abdomen, appeared to be in great pain, and spoke with difficulty. Covington stated that Bryant (D) shot him at around 3 a.m. He had a conversation with D, whom he recognized based on his voice, through the back door of D's house. Covington explained that when he turned to leave, he was shot through the door and then drove to the gas station, where police found him. Within 5 to 10 minutes emergency medical services arrived and Covington was transported to a hospital and died within hours. Police traveled to D's house. They found blood and a bullet on the back porch and an apparent bullet hole in the back door. Police found Covington's wallet and identification outside the house. The trial occurred prior to the decisions in Crawford and Davis. The police officers who spoke with Covington at the gas station testified about what Covington had told them. The jury returned a guilty verdict on charges of second-degree murder, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony. D appealed, and the Michigan Court of Appeals affirmed his conviction. Bryant then appealed to the Supreme Court of Michigan, arguing that the trial court erred in admitting Covington's statements to the police. On remand, the Court of Appeals again affirmed, holding that Covington's statements were properly admitted because they were not testimonial. The Supreme Court of Michigan concluded that the circumstances 'clearly indicate that the `primary purpose' of the questioning was to establish the facts of an event that had already occurred; the `primary purpose' was not to enable police assistance to meet an ongoing emergency.' The Supreme Court granted certiorari to determine whether the Confrontation Clause barred admission of Covington's statements.