Langley v. State

At the time we granted certiorari and heard oral argument here, this case presented an emerging issue that plagued courts nationwide: determining whether the content of 9-1-1 telephone calls made following the apparent completion of a discrete crime or crimes is considered “testimonial,” and thus inadmissible under Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004), when offered without a live witness—the caller. The Supreme Court’s recent Michigan v. Bryant, — U.S. -, 131 S.Ct. 1143, 179 L.Ed.2d at 93 (2011), however, provides some clarity in what theretofore was a…