In Michigan v. Bryant, the United States Supreme Court wrote another chapter in the clash between the Confrontation Clause of the Sixth Amendment to the United States Constitution and the admissibility of extra-judicial statements. This article presents an outline of Bryant’s “ongoing emergency” doctrine, an examination of how Bryant may affect Massachusetts’s decisional law, and a view that Bryant’s holding and dictum may mark a return to the basic contours of the reliability of excited utterances in the context of domestic violence prosecutions. . .
