On the Job 

Ohio v. Clark, U.S. Supreme Court, 135 S.Ct. 2173, June 18, 2015
 
The U.S. Supreme Court unanimously reversed the Supreme Court of Ohio in Ohio v. Clark.
 
Brief facts
A preschool teacher noticed that one of the students, a 3-year-old boy, had bruises and a bloodshot eye. When teachers questioned the boy about what happened, he made statements that identified his mother’s boyfriend, Darius Clark, as the source of the injuries.
    
Clark was charged with multiple counts of child endangerment, felonious assault and domestic violence. The boy was found incompetent to testify by the trial court due to his young age. Clark moved to exclude the boy’s statements to his teachers on the grounds that the statements were testimonial because their primary purpose was to create evidence against Clark. The trial court disagreed. Because the statements were non-testimonial they were allowed to be introduced. The jury found Clark guilty and he was sentenced to 28 years in prison. 
 
Ohio law
The 8th District Court of Appeals reversed the trial court and the Supreme Court of Ohio agreed, finding that a child’s statement to teachers about physical abuse is testimonial in nature because teachers have mandatory reporting requirements under Ohio law.
 
U.S. Supreme Court findings 
In its review of the case, the U.S. Supreme Court found that the child’s statements to his teachers were non-testimonial. The U.S. Supreme Court held that mandatory reporting requirements do not automatically convert a conversation between a teacher and a student into a law enforcement mission designed to gather evidence, and the statements should be allowed to be introduced.