Crawford v. Washington
Supreme Court of the United States · Decided March 8, 2004 · Core case
Full citation
Crawford v. Washington, 541 U.S. 36 (2004).
VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 20, 2026.This brief explains the opinion as issued. Later treatment and current-law status are not assessed here.
Michael Crawford
criminal defendantpetitioner
Washington
staterespondent
Brief
Facts
On August 5, 1999, Kenneth Lee was stabbed at his apartment. Police arrested Michael Crawford later that night. After giving Crawford and his wife, Sylvia, Miranda warnings, detectives interrogated each of them twice. Crawford confessed that he and Sylvia had gone in search of Lee because he was upset over an earlier incident in which Lee had tried to rape her. They found Lee at his apartment, and a fight ensued in which Lee was stabbed in the torso and Crawford's hand was cut. Crawford said he thought Lee had pulled something out, though he was not positive. Sylvia generally corroborated Crawford's account of the events leading up to the fight, but her tape-recorded account of the fight itself may have differed, particularly on whether Lee had drawn a weapon before Crawford assaulted him. She said Lee had nothing in his hands after he was stabbed. The State charged Crawford with assault and attempted murder. At trial, he claimed self-defense. Sylvia did not testify because of the state marital privilege, which generally bars a spouse from testifying without the other spouse's consent. In Washington, the privilege does not extend to a spouse's out-of-court statements admissible under a hearsay exception. Because Sylvia admitted leading Crawford to Lee's apartment, the State invoked the hearsay exception for statements against penal interest and played her tape-recorded statement to the jury. Crawford had no opportunity to cross-examine her. The jury convicted him of assault.
Issue
Does the admission of an unavailable witness's tape-recorded testimonial statement against a criminal defendant violate the Sixth Amendment's Confrontation Clause when the defendant had no prior opportunity to cross-examine the witness, even if a court finds the statement reliable under judicial balancing tests?
Holding
The State admitted Sylvia Crawford's tape-recorded statement obtained during police interrogation against Crawford without providing him an opportunity to cross-examine her. Because her statement was testimonial and Crawford had no opportunity for cross-examination, its admission violated the Confrontation Clause, regardless of whether a court found the statement reliable. The Washington Supreme Court's judgment upholding Crawford's conviction was reversed.
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