Court Grants Cert. in Two Crawford-Related Cases

Today the Court agreed to hear two cases involving the application of Crawford v. Washington to 911 phone calls and excited utterances.  Leonard Post has this interesting article in the National Law Journal discussing the issues.  I'll blog about these cases ad nauseum, but quickly, I think that 911 statements should not be subject to Crawford, while excited utterances should be.  When someone makes a 911 call, he is asking for help.  ("Please hurry!  This is an emergency!") When someone makes an excited utterance, she is "telling" on someone.  ("That no-good-SOB did ...")  Asking for help generally doesn't make one an "accuser," where as telling on someone generally does.