California, United States of America
The following excerpt is from People v. Robles, B232828 (Cal. App. 2014):
In Michigan v. Bryant (2011) 562 U.S. ___ [131 S.Ct. 1143], police found the mortally wounded victim in a parking lot. His statements identifying his shooter and describing the shooting were not testimonial, because their primary purpose was to enable police to respond to an ongoing emergency. (Id. at p. 1150.) The statements were also not sufficiently formal: they were made in an exposed, public area, in a disorganized fashion, before emergency medical services arrived. (Id. at p. 1160; see also People v. Blacksher (2011) 52 Cal.4th 769, 811-816.)
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