Ohio v. Clark
United States Supreme Court
576 U.S. 1 (2015)
When three-year-old L.P.'s preschool teachers noticed his bloodshot eye and bruises, they asked him who had hurt him, and he identified his father, Clark (defendant); L.P. himself was ruled incompetent to testify under state law, but his statements to the teachers were introduced at Clark's child-abuse trial over his Confrontation Clause objection. The trial court found the statements non-testimonial and admitted them, the jury convicted Clark, the court of appeals reversed, the Ohio Supreme Court affirmed that reversal, and the U.S. Supreme Court granted certiorari.
Whether out-of-court statements made to persons other than law-enforcement officers are excluded from admission into evidence by the Confrontation Clause.