Prior to Crawford v.Washington, if a form of statement was traditionally recognized as an exception to the hearsay rule it was also recognized as an exception to the

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Prior to Crawford v. Washington, hearsay exceptions were also automatically considered exceptions to the Confrontation Clause, meaning that the defendant's right to confront and cross-examine witnesses against them was not violated by the admission of such statements. Crawford changed this precedent and held that some hearsay exceptions may still violate the Confrontation Clause if they lack indicia of reliability or were testimonial in nature.

Prior to Crawford V