California, United States of America
The following excerpt is from People v. Armstrong, C079636 (Cal. App. 2018):
Although a statement made during a police interrogation may be testimonial, when the primary purpose of the interrogation is to "respond to an 'ongoing emergency,' its purpose is not to create a record for trial and thus is not within the scope of the [confrontation clause]." (Michigan v. Bryant, supra, 562 U.S. at p. 358.) To determine
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