The People v. Cid C. Franklin

Summary

The court held that the Criminal Justice Agency interview report was not testimonial under the Confrontation Clause because its objectively determined primary purpose was administrative: assessing the defendant's suitability for pretrial release, not creating a substitute for trial testimony. The court rejected the approach that turns solely on whether an out-of-court statement establishes an essential element of the charged offense and concluded that the report was admissible for confrontation purposes. The order reversing the conviction was reversed, and the case was remitted for consideration of unresolved issues.