In Crawford v. Washington and Davis v. Washington, the United States Supreme Court profoundly changed how hearsay statements are analyzed under the Confrontation Clause. If a hearsay statement is “testimonial,” then the statement cannot be admitted against a criminal defendant unless the defendant had the opportunity to cross-examine the hearsay declarant. Testimonial statements include many, if not most, statements to law enforcement, particularly if elicited through structured interviews and captured on tape. The full reach of the “testimonial” concept, however, has not been determined.