[1] In Bryant, the Court expanded upon the test first articulated in Davis v. Washington, "addressing for the first time circumstances in which the 'ongoing emergency' discussed in Davis extended to a potential threat to the respond police and the public at large.

"[1] The Court stated that determination of whether an interrogation's primary purpose was to assist in an "ongoing emergency" was an objective evaluation of the circumstances "in which the encounter occur[ed] and the statements and actions of the parties.

"[1] Detroit Police Department officers were dispatched to a gas station parking lot and found Anthony Covington severely wounded lying next to his car.

Ultimately, the Michigan Supreme Court reversed Bryant's conviction, holding that the Sixth Amendment's Confrontation Clause, as explained in Crawford v. Washington (2004), rendered Covington's statements inadmissible testimonial hearsay.

[3] The United States Supreme Court reversed and remanded the Michigan Supreme Court's ruling, and held that the victim's statements were not testimonial hearsay, meaning the Confrontation Clause did not bar the admission of the evidence.