In civil contempt proceedings to enforce child support, “where . . . the custodial parent (entitled to receive the support) is unrepresented by counsel, the State need not provide counsel to the noncustodial parent (required to provide the support),” subject to the “caveat . . . that the State must nonetheless have in place alternative procedures that assure a fundamentally fair determination of the critical incarceration-related question, whether the supporting parent is able to comply with the support order.”
C. Thomas
Michigan v. Bryant, No. 09–150, __ U.S. __ (Feb. 28, 2011)
Statement of mortally wounded victim to police was not “testimonial” under Crawford Confrontation Clause holding because circumstances indicated “primary purpose” of the police questions eliciting statement was to “meet an ongoing emergency.”
Maryland v. Shatzer, No. 08–680, __ U.S. __ (Feb. 24, 2010)
Adopts a brightline rule that a fourteen-day break in Miranda custody ends the presumption of involuntariness established in Edwards v. Arizona for responses to police-initiated questioning after a subject has invoked the right to have Miranda counsel present during interrogation; a subject incarcerated for an unrelated crime is not in Miranda custody for purposes of this fourteen-day rule.
Presley v. Georgia, No. 09-5270, __ U.S. __ (Jan. 19, 2010)
Defendant’s Sixth Amendment public trial right requires that jury selection be open to the public.
Melendez-Diaz v. Massachusetts, No. 07-591, __ U.S. __ (June 25, 2009)
Admission of government lab technicians’ sworn “certificates of analysis” that substance taken from defendant was cocaine violated defendant’s Sixth Amendment Confrontation Clause right; the certificates were “affidavits” and within the “core class of testimonial statements” defined in Crawford v. Washington.