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Name: People v. Adams
Case #: C040891
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 07/22/2004
Subsequent History: Rev. granted 10/13/04: S127373
Summary

Admission of a victim’s statements to sheriff deputies violates the defendant’s 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.