State v. Clark

[Cite as State v. Clark, 137 Ohio St.3d 346,

2013-Ohio-4731.] THE STATE OF OHIO, APPELLANT, v. CLARK, APPELLEE. [Cite as State v. Clark, 137 Ohio St.3d 346,

2013-Ohio-4731.] Criminal law—Confrontation Clause—R.C. 2151.421—A teacher acts in a dual capacity as an instructor and as an agent of the state for law-enforcement purposes when questioning a child about suspected abuse in furtherance of the teacher’s duty to report abuse—Statements elicited from a child by a teacher in the absence of an ongoing emergency and for the primary purpose of gathering information of past criminal conduct and…