When prosecuting domestic violence cases, too many officers build the entire case solely on statements made by the victim. However, “victims of domestic violence are more likely than victims of other violent crimes to recant or refuse to cooperate in judicial efforts” (Breitenbach, 2008, p. 1256). Officers should consider that victims of domestic violence may refuse to testify out of fear of retaliation, intimidation, financial dependence, emotional attachment, and/or because they have reunited with the abuser. If the victim refuses to testify in court, her statement against the abuser becomes hearsay evidence. Several recent cases have had a huge influence on how such hearsay statements and evidence can be used in court without victim testimony. In 2004, the Supreme Court ruled on Crawford v. Washington and held that testimonial statements did not constitute exceptions to hearsay. rule (Breitenbach, 2008). Since the purpose of a witness statement was to prove and/or establish the facts in a case, the defendant had the right to cross-examine that testimony. This right was called the comparison clause. Because of the confusion created by the Crawford standard, the Supreme Court provided more parameters in Davis v Washington in June 2006 (Ewing, 2007). Davis ruled the victims' accounts as either testimonial or non-testimonial. The courts also found that this included statements made during an interrogation conducted by law enforcement. If the statements had been obtained by law enforcement to determine an ongoing emergency, they would have been identified by the court as non-testimonial and not subject to the requirements of the confrontation clause. If the statements we...... half of the document ......ion of the victim. Works Cited Breitenbach, K.G. (2008, Fall). Combating the Threat: Successful Domestic Violence Prosecution After Davis v. Washington. Albany Law Review, 71(4), 1255+. Retrieved from http://go.galegroup.com/ps/i.do?id=GALE%7CA200252467&v=2.1&u=chazsu_main&it=r&p=AONE&sw=wByrom, C.E. (2005). The use of the enthusiastically expressed hearsay exception in the prosecution of domestic violence cases after Crawford v. Washington. Litigation Review, 24(2), 409-428.Ellison, L.L. (2002). Prosecuting domestic violence without the participation of the victim. Modern Law Review, 65(6), 834-858.Ewing, D. (2007). Pursuing hitters in the wake of Davis and Hammon. American Journal Of Criminal Law, 35(1), 91-106.Pence, E. & Paymar, M. (2001). Domestic violence: the response of law enforcement. Minneapolis, MN: Law Enforcement Resource Center.