legal proceedings but are initiated by a victim or witness to obtain police assistance. See People v. Corella, 122 Cal.App.4th 461, 18 Cal.Rptr.3d 770, 776 (Ct.App.2004); People v. Moscat, 3 Misc.3d 739, 777 N.Y.S.2d 875, 879-80 (Crim.Ct.2004); State v. Davis, 111 P.3d 844, 849 (Wash.2005). They usually do not bear any of the official, formal qualities of the police interactions the Confrontation Clause was intended to protect against. See Corella, 18 Cal.Rptr.3d at 776; Moscat, 111 N.Y.S.2d at 879-80; Davis, 111 P.3d at 850-51. Some courts have held that statements made during 911 calls should be analyzed on a case-by-case basis because some statements could be testimonial under certain circumstances. See People v. West, 355 Ill.App.3d 28, 291 Ill.Dec. 72, 823 N.E.2d 82, 91 (2005) (<HOLDING>); People v. Mackey, 5 Misc.3d 709, 785 N.Y.S.2d
holding that accusers 911 call initial statement to police upon their arrival at the crime scene and statements made to police a short time later were testimonial holding that 911 calls should be analyzed on a casebycase basis to determine whether statements at issue were volunteered to obtain police action or the result of interrogation to gather evidence for use in a criminal prosecution holding that whether a statement made in response to interrogation is testimonial depends on whether the objective purpose of the interrogation was to establish or prove past events potentially relevant to later criminal prosecution or to meet an ongoing emergency holding that statements made to the police during a field investigation should be analyzed on a casebycase basis and establishing an eightfactor test that includes consideration of the purpose of both the declarant and the officer holding that the district court did not err in admitting evidence of an allegedly coerced interrogation where the taped interrogation was played for jurors and the defendant crossexamined the witness at length about the interrogation