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STATE v. AGUILAR

No. 1 CA-CR 02-0079.

107 P.3d 377 (2005)

210 Ariz. 51

STATE of Arizona, Appellee, Cross-Appellant, v. Tonatihu AGUILAR, Appellant, Cross-Appellee.

Court of Appeals of Arizona, Division 1, Department A.

March 3, 2005.

Attorney(s) appearing for the Case

Terry Goddard, Attorney General, by Randall M. Howe, Chief Counsel, Criminal Appeals Section and Katia Mehu, Assistant Attorney General, Phoenix, Attorneys for Appellee.

James J. Haas, Maricopa County Public Defender, by Joel M. Glynn, Assistant County Public Defender, Phoenix, Attorneys for Appellant.

OPINION

SULT, Judge.

¶ 1 Sixth Amendment confrontation clause analysis significantly changed with the United States Supreme Court's decision in Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004). Crawford holds that "testimonial" out-of-court statements by unavailable declarants, including those statements previously admissible as firmly rooted hearsay exceptions, cannot be admitted...

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