Admission of a victims statements to sheriff deputies violates the defendants right to confront witnesses under Crawford v. Washington (2004) 158 L.Ed.2d 177. Pursuant to Evidence Code section 1370, the court below admitted statements the victim made regarding the instant case and a previous uncharged offense. Both statements were made to law enforcement officers, and the victim did not testify at trial. Citing Crawford, the Court of Appeal held that the evidence was improperly admitted, and the error was not harmless beyond a reasonable doubt.
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