Ohio v. Clark

E822925

Ohio v. Clark is a 2015 U.S. Supreme Court decision that clarified the limits of the Confrontation Clause in the context of statements made by child abuse victims to non-law-enforcement individuals.

All labels observed (2)

Label Occurrences
Ohio v. Clark canonical 2
Ohio v. Clark, 576 U.S. 237 (2015) 1

How this entity was disambiguated

Statements (48)

Predicate Object
instanceOf Confrontation Clause case ⓘ
United States Supreme Court case ⓘ
criminal procedure case ⓘ
appliedPrecedent Crawford v. Washington ⓘ
Davis v. Washington ⓘ
Michigan v. Bryant ⓘ
areaOfLaw constitutional criminal procedure ⓘ
evidence law ⓘ
citation 576 U.S. 237 ⓘ
citationStyle Ohio v. Clark, 576 U.S. 237 (2015) ⓘ
linked to: Ohio v. Clark
constitutionalProvisionInterpreted Sixth Amendment to the United States Constitution ⓘ
court Supreme Court of the United States ⓘ
decisionDate 2015-06-18 ⓘ
docketNumber 13-1352 ⓘ
factsSummary A three-year-old child with visible injuries identified his mother’s boyfriend, Darius Clark, as the abuser when questioned by preschool teachers. ⓘ
fullName Ohio v. Clark ⓘ
holding Statements made by a child to his teachers about suspected abuse were not testimonial and their admission at trial did not violate the Confrontation Clause. ⓘ
impact clarified that statements by very young children to teachers about abuse can be admitted without violating the Confrontation Clause when not primarily intended as testimony. ⓘ
narrowed the circumstances in which out-of-court statements are considered testimonial. ⓘ
joinedByInMajority Anthony M. Kennedy ⓘ
Antonin Scalia ⓘ
Clarence Thomas ⓘ
Elena Kagan ⓘ
John G. Roberts Jr. ⓘ
Ruth Bader Ginsburg ⓘ
Sonia Sotomayor ⓘ
Stephen G. Breyer ⓘ
jurisdiction United States ⓘ
legalIssue scope of the Sixth Amendment Confrontation Clause ⓘ
statements by child abuse victims to non-law-enforcement personnel ⓘ
testimonial versus nontestimonial hearsay ⓘ
majorityOpinionBy Samuel A. Alito Jr. ⓘ
originatingJurisdiction State of Ohio ⓘ
linked to: Ohio
petitioner State of Ohio ⓘ
linked to: Ohio
proceduralHistory Ohio courts held that admission of the child’s statements to teachers violated the Confrontation Clause. ⓘ
relatedTo child protective reporting statutes ⓘ
mandatory reporter obligations of teachers ⓘ
respondent Darius Clark ⓘ
resultForRespondent conviction reinstated ⓘ
reversed judgment of the Supreme Court of Ohio ⓘ
ruleOfLaw Mandatory reporting duties of teachers do not by themselves transform conversations with students into law-enforcement interrogations. ⓘ
Statements are testimonial when their primary purpose is to create an out-of-court substitute for trial testimony. ⓘ
Statements to individuals who are not law enforcement officers are less likely to be testimonial. ⓘ
subjectMatter child abuse ⓘ
criminal prosecution for assault and related offenses ⓘ
hearsay evidence ⓘ
term October Term 2014 ⓘ
vote 9-0 ⓘ

How these facts were elicited

Referenced by (3)

Full triples — surface form annotated when it differs from this entity's canonical label.

Ohio v. Clark → fullName → Ohio v. Clark ⓘ
Ohio v. Clark → citationStyle → Ohio v. Clark, 576 U.S. 237 (2015) ⓘ
linked to: Ohio v. Clark