Anderson v. State

111 P.3d 350, 2005 Alas. App. LEXIS 40, 2005 WL 858773
CourtCourt of Appeals of Alaska
DecidedApril 15, 2005
DocketA-8064
StatusPublished
Cited by18 cases

This text of 111 P.3d 350 (Anderson v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Alaska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. State, 111 P.3d 350, 2005 Alas. App. LEXIS 40, 2005 WL 858773 (Ala. Ct. App. 2005).

Opinions

OPINION

COATS, Chief Judge.

In the early morning of December 1, 2000, the Anchorage police received a 911 call from a woman; the woman reported that she had been physically assaulted. When a police officer arrived on the scene, the woman told the officer that someone else was hurt. The woman led the officer to a nearby apartment, where a man was lying on the floor. When the officer asked this man what had hap[351]*351pened, the man answered that “Joe” — the defendant, Joseph L. Anderson — had hit him with a pipe.

At Anderson’s trial, the injured man did not testify, but his out-of-court statement was presented to the jury through the hearsay testimony of the police officer. The trial judge ruled that the man’s statement was admissible as an excited utterance under Alaska Evidence Rule 803(2). In our first decision in Anderson’s case, we upheld that evidentiary ruling.1

Now, however, we must decide a question of federal constitutional law: Even though the injured man’s statement was admissible as an excited utterance under Alaska Evidence Rule 803(2), was the police officer’s hearsay testimony concerning this out-of-court statement barred by the Confrontation Clause of the United States Constitution?

In Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004), the United States Supreme Court construed the Confrontation Clause to prohibit the government from introducing hearsay testimony describing “testimonial” out-of-court statements (unless the government proves (a) that the person who made the out-of-court statements is unavailable as a witness and (b) that the defendant had a prior opportunity to cross-examine this person concerning those statements). The issue in Anderson’s case is whether the injured man’s response to the officer’s question, “What happened?”, qualifies as “testimonial” hearsay under Crawford.

For the reasons explained here, we conclude that the injured man’s response was not “testimonial” for purposes of the Confrontation Clause. Because hearsay testimony concerning this out-of-court statement was not barred by the Confrontation Clause, and because (as we concluded in our previous decision) the statement was admissible as an excited utterance under Alaska’s evidence rules, Anderson’s trial judge properly allowed the police officer to testify concerning the injured man’s out-of-court statement.

Facts and proceedings

In the early morning of December 1, 2000, Zonyua Robinson placed a 911 call to the Anchorage Police Department. Robinson informed the police that Joseph Anderson had just assaulted her.

Anchorage Police Officer Pam Nelson was dispatched to the Arctic Tern Inn to contact Robinson. When Officer Nelson contacted Robinson, she was bleeding and was very upset. Robinson told Officer Nelson that there was someone else who was hurt and needed help. She led the officer to a nearby apartment, where an injured man — Carroll Nelson — was lying on the floor, covered with a blanket or bedspread.

According to Officer Nelson’s later testimony, Robinson asked Carroll Nelson if he was all right. Carroll Nelson replied that he was hurt, and that he was having a hard time breathing. When Officer Nelson removed the covering from Carroll Nelson’s body, she observed that Nelson was not wearing a shirt, and that he had several obvious bruises on his torso. According to Officer Nelson, Carroll Nelson appeared to be in a lot of pain.

At this point, Officer Nelson asked him, “What happened?” Carroll Nelson responded that “Joe” had hit him with a pipe.

Carroll Nelson did not testify at Anderson’s trial. However, Officer Nelson was allowed to testify concerning this out-ofT court statement. The trial judge ruled that Carroll Nelson’s response to the officer’s question was admissible as an excited utterance under Alaska Evidence Rule 803(2).

Later, when Anderson appealed his conviction to this Court, we affirmed this evi-dentiary ruling. In reaching this conclusion, we relied on the United States Supreme Court’s decision in Ohio v. Roberts.2 In Roberts, the Supreme Court ruled that the hearsay exception for excited utterances was a “firmly rooted hearsay exception,” and thus any out-of-court statement that qualified as an excited utterance inherently car[352]*352ried sufficient indicia of trustworthiness to satisfy the Confrontation Clause of the United States Constitution.3

Following our decision, Anderson petitioned the Alaska Supreme Court to hear his case. While Anderson’s petition was pending, the United States Supreme Court decided Crawford v. Washington. In Crawford, the Supreme Court overruled Ohio v. Roberts and announced a new interpretation of the Confrontation Clause. Crawford holds that the Confrontation Clause flatly prohibits the government from introducing “testimonial” hearsay, no matter how much the circumstances surrounding the making of the out-of-court statement might indicate that the statement is trustworthy, unless the defendant has had a prior opportunity to cross-examine the speaker regarding the out-of-court statement, and unless the government demonstrates that the speaker is unavailable to testify at the defendant’s trial.

Because Crawford announced a new Confrontation Clause analysis, the Alaska Supreme Court remanded Anderson’s ease to us so that we might reconsider our decision in light of Crawford.

Crawford v. Washington

Michael D. Crawford was tried in the State of Washington for assault and attempted murder. Crawford had stabbed Kenneth Lee and claimed self defense. Crawford’s wife, Sylvia, had seen the stabbing and had been extensively interrogated by the police soon afterwards. Sylvia did not testify at Crawford’s trial because Crawford exercised Washington’s marital privilege, which bars a spouse from testifying without the other spouse’s consent. But the State was able to introduce, over Crawford’s objections, Sylvia’s tape-recorded statements to the police, which the State offered as evidence that Crawford had not stabbed Lee in self defense. The State argued that Sylvia’s statement was admissible, although hearsay, because it was a statement against penal interest.4 The trial court and the Washington Supreme Court concluded that admission of Sylvia’s statement did not violate Crawford’s federal constitutional right to confrontation. The courts relied on Ohio v. Roberts. The Washington Supreme Court concluded that, although Sylvia’s statement did not fall under a firmly-rooted hearsay exception, the statement had sufficient guarantees of trustworthiness to satisfy the Confrontation Clause.5 The United States Supreme Court granted certiorari.

In the Crawford decision, the Supreme Court reexamined its decision in Ohio v. Roberts. Under Ohio v. Roberts, a witness’s out-of-court statement could be admitted if it had “adequate indicia of reliability.” A statement had adequate indicia of reliability if it fell within a “firmly rooted hearsay exception” or had “particularized guarantees of trustworthiness.”6 But in Crawford, the Court concluded that the Ohio v. Roberts test was fundamentally flawed.

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Anderson v. State
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Bluebook (online)
111 P.3d 350, 2005 Alas. App. LEXIS 40, 2005 WL 858773, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-state-alaskactapp-2005.