In Crawford v. Washington, 124 S. Ct. 1354 (2004), the U.S. Supreme Court radically transformed its doctrine governing the Confrontation Clause of the Sixth Amendment to the U.S. Constitution. Craitiord is a very positive development, restoring to its central position one of the basic protections of the common law system of criminal justice. But the decision leaves many open questions, and all lawyers involved in the criminal justice process will have to adjust to the new regime that it creates. This article outlines and summarizes the problems with the law as it stood before Crait/brd. It then explains the theoretical basis for Crawford; and shows how the case has altered prior law in some respects and in others left matters as they were beforehand. Finally, it discusses some of the important questions that are likely to arise under Crciijbrd and some changes in law that-for better or worse- might be adopted in response to the decision.
Friedman, Richard D. "Adjusting to Crawford: High Court Decision Restores Confrontation Clause Protection." Crim. Just. 19, no. 2 (2004): 4-13.