State v. Clark

I agree with the majority that, even if the trial court erroneously admitted the testimonial statements in violation of Crawford, such error was harmless in light of the overwhelming evidence of Defendant’s guilt. I do not agree with the majority’s discussion of Crawford, however, and I therefore concur in the result only.

In this case, the majority opinion analyzes multiple issues in light of Crawford, but ultimately concludes that all such errors were harmless. Inasmuch as the United States Supreme Court deliberately left its holding in Crawford with unsettled issues, and the errors in this…