Hartsfield v. Commonwealth

277 S.W.3d 239, 2009 Ky. LEXIS 37, 2009 WL 425008
CourtKentucky Supreme Court
DecidedFebruary 19, 2009
Docket2007-SC-000077-DG
StatusPublished
Cited by40 cases

This text of 277 S.W.3d 239 (Hartsfield v. Commonwealth) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hartsfield v. Commonwealth, 277 S.W.3d 239, 2009 Ky. LEXIS 37, 2009 WL 425008 (Ky. 2009).

Opinions

Opinion of the Court by

Chief Justice MINTON.

We granted Tyrone Hartsfield’s motion for discretionary review of a Court of Appeals opinion that held that the prosecution’s use at trial of statements made by an alleged sexual assault victim, who died after the return of the indictment but before trial, would not violate the Sixth Amendment’s Confrontation Clause. We granted review of this issue because of the significant impact the United States Supreme Court’s analysis of the Confrontation Clause in Crawford v. Washington1 has on trial practice in Kentucky.

We reverse the Court of Appeals, in part, because we conclude that the alleged victim’s statements to an investigative nurse were testimonial in nature; and their admission into evidence at trial would violate Hartsfield’s confrontation rights. But we affirm the Court of Appeals, in part, because we conclude that excited utterances made by the victim to lay witnesses were not testimonial in nature; and their admission at trial would not violate the Confrontation Clause. We remand to the trial court for further proceedings consistent with this opinion.

I. FACTUAL AND PROCEDURAL BACKGROUND.

A grand jury indicted Hartsfield on charges of multiple sexual crimes involving three separate female victims, one of whom was M.B. The indictment charged Hartsfield with the first-degree rape and the first-degree sodomy of M.B. M.B. died before the indictment came to trial, pi'ompting Hartsfield’s motion to dismiss the counts in. the indictment relating to M.B. on the ground that M.B.’s statements concerning the alleged crimes were inadmissible hearsay. The trial court denied the motion to dismiss. The Commonwealth then moved in limine to establish affirmatively the admissibility of M.B.’s statements. The first of the motions concerned M.B.’s statements to a nurse; the second motion concerned two statements made to two separate individuals following the incident, which were described as excited utterances.2

Following the alleged sexual assaults, M.B. had been taken to a hospital where she was examined by a Sexual Assault Nurse Examiner (abbreviated SANE and informally referred to as a SANE nurse).3

[242]*242M.B. related the details of the rape to the SANE nurse, who also collected samples using a rape test kit.

As for the statements claimed by the Commonwealth to be admissible as excited utterances, the Commonwealth stated that M.B. fled her house immediately after the rape and encountered a passerby named Malcolm Buchanan. M.B. was crying and yelled, “He raped me; he raped me.”4 In addition, the Commonwealth reported that M.B. ran to her daughter’s house and told her daughter she had just been raped. The record indicates M.B.’s statement to her daughter was made close in time and proximity to the alleged rape.

Following a hearing, the trial court excluded all of the statements as an abridgment of Hartsfield’s right to cross-examine the witnesses against him. The court further ordered the counts regarding M.B. to be dismissed. In light of the rulings in limine, the Commonwealth and Hartsfleld then reached a plea agreement whereby Hartsfleld pleaded guilty to the other amended counts of the indictment.5 The Commonwealth then appealed from the trial court’s order overruling the motions in limine and dismissing the counts of the indictment as to M.B. The Court of Appeals reversed the trial court on the belief that all of the statements were covered by hearsay exceptions and, in particular, that the statements to the SANE nurse did not run afoul of the Confrontation Clause because they were not made by M.B. for the purpose of causing the nurse to testify on her behalf.

II. ANALYSIS.

The determination of the admissibility of evidence is within the sound discretion of the trial court.6 A trial court abuses its discretion when its decision is arbitrary, unreasonable, unfair, or unsupported by sound legal principles.7 In this instance, we must resolve whether the trial court applied the correct legal principle.

Hartsfleld asserts that the admission of any of these statements would violate his right to confront adverse witnesses under the Sixth Amendment’s Confrontation Clause. The United States Supreme Court held in Crawford v. Washington8 that the Confrontation Clause precludes admission of the statements of a witness unavailable to testify at trial if the witness’ out-of-court statements were “testimonial,” unless the accused had a prior opportunity to cross-examine the witness.9 Before Crawford, the Clause had been interpreted to allow admission of an unavailable witness’s out-of-court statement if it possessed adequate indicia of reliability. Before Crawford, the admissibility question was whether the statement fell within a firmly rooted hearsay exception or pos[243]*243sessed other particularized guarantees of trustworthiness.10 The Supreme Court in Crawford rejected that analysis as incompatible with the Framers’ intent in creating the Confrontation Clause.11

Since Crawford, the threshold examination to determine a Confrontation Clause violation is whether the proffered out-of-court statement was testimonial Examples of testimonial statements given in Crawford included prior testimony at a preliminary hearing, before a grand jury, or at a former trial; and statements made in response to police interrogations.12 But the Supreme Court did not otherwise provide a comprehensive definition of what is encompassed by the term testimonial.

The Court referenced several “formulations of ... ‘testimonial’ statements” in Crawford in its opinion: (1) “ex 'parte in-court testimony or its functional equivalent — that is, material such as affidavits, custodial examinations, prior testimony that the defendant was unable to cross-examine, or similar pretrial statements that declarants would reasonably expect to be used prosecutorially”;13 (2) “extrajudicial statements ... contained in formalized testimonial materials, such as affidavits, depositions, prior testimony, or confessions”; 14 and (3) “statements that were made under circumstances which would lead an objective witness reasonably to believe that the statement would be available for use at a later trial.” 15 The Court did not select any of these formulations as the definitive test to apply. And the Court did say that where nontestimonial hearsay is at issue, it is consistent with the Constitution to allow the states the development of their own hearsay law.16

Since Crawford, the Supreme Court addressed the question of which police interrogations qualify as testimonial in two decisions, Davis v. Washington, and its companion case, Hammon v. Indiana.17 In Davis, the Court held that a domestic violence victim’s 911 call for help and her responses to the emergency operator’s questions were nontestimonial and, therefore, not subject to the Confrontation Clause. In Hammon,

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Cite This Page — Counsel Stack

Bluebook (online)
277 S.W.3d 239, 2009 Ky. LEXIS 37, 2009 WL 425008, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hartsfield-v-commonwealth-ky-2009.