Skip to main content

Children's statements to teachers

Ohio v. Clark

Updated Oct 26, 2026

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.

Illustration for Ohio v. Darius Clark
Conceptual illustration · AI-generated

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
Majority · 6joined the Court's opinion
  1. Breyer
  2. Kagan
  3. Kennedy
  4. Sotomayor
  5. Roberts
  6. Alitowrote the opinion
Concurring · 3agreed with the result, wrote separately
  1. Thomaswrote separately
  2. Scaliawrote separately
  3. Ginsburg
9 justices joined the judgment (3 writing separately).

What's next

The case returns to the Supreme Court of Ohio for further proceedings.

Documents

1

Docket activity

9
  • New analysis added

    Oct 26, 2026 · Court records

  • AI analysis generated: Case Briefing

    Oct 26, 2026 · Generated

  • New analysis added

    Oct 26, 2026 · Court records

  • AI analysis generated: Impact Analysis

    Oct 26, 2026 · Generated

  • AI analysis generated: Opinion Summary

    Oct 26, 2026 · Generated

Show 4 more
  • AI analysis generated: Decision Record

    Oct 26, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Oct 26, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Oct 17, 2026 · Court records

  • Opinion added: Opinion

    Jun 18, 2015 · Court records

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.

Checked Oct 26, 2026Methodology

Court records and filings

Reporting and analysis