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USING THE CRAWFORD v. WASHINGTON “FORFEITURE BY …
www.ncdsv.orgUSING THE CRAWFORD v.WASHINGTON “FORFEITURE BY WRONGDOING” CONFRONTATION CLAUSE EXCEPTION IN CHILD ABUSE CASES. By Tom Harbinson1 INTRODUCTION In Crawford v.Washington,2 the United States Supreme Court held that when an out-of- court statement of an unavailable witness is testimonial, the Sixth Amendment requires