Children's statements to teachers
Ohio v. Clark
In brief
The Supreme Court ruled that using L. P.’s statements did not violate Clark’s rights, overturned Ohio’s ruling, and sent the case back.
- Where it stands
- Decided
Decided 9-0 · June 18, 2015 · Opinion by Justice Alito
- What it’s about
- The Supreme Court ruled that using three-year-old L. P.’s statements to his preschool teachers at Darius Clark’s trial did not violate Clark’s Sixth Amendment right to question witnesses (the Confrontation Clause).
- Who it affects
- For Clark’s trial, the Court decided that admitting L. P.’s statements did not violate his Sixth Amendment right to question witnesses.
Summary: written with AI from the case record.

What it's about
It overturned the Ohio Supreme Court’s judgment and sent the case back to that court (remanded).
The child, identified as L. P., was three years old and had made the statements to his preschool teachers.
The Sixth Amendment gives a person accused of a crime the right to question witnesses whose statements are used at trial.
Question presented
1. Does an individual’s obligation to report suspected child abuse make that individual an agent of law enforcement for purposes of the Confrontation Clause? 2. Do a child’s out-of-court statements to a teacher in response to the teacher’s concerns about potential child abuse qualify as “testimonial” statements subject to the Confrontation Clause?
What the Court decided
Holding
The introduction of L. P.’s statements at trial did not violate the Confrontation Clause. 3d 346, 2013–Ohio–4731, 999 N. E. 2d 592, reversed and remanded.
- Result
- Reversed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Concurring · 3agreed with the result, wrote separately
- Thomaswrote separately
- Scaliawrote separately
- Ginsburg
What's next
The case returns to the Supreme Court of Ohio for further proceedings.
Documents
Opinions
Docket activity
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AI analysis generated: Case Briefing
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
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Opinion added: Opinion
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.