be the minority view. See Contreras v. State, 910 So.2d 901, 912-13 (Fla.Dist.Ct.App. Sept.14, 2005) (May, J., dissenting) (noting that “Lopez has been distinguished and disagreed with by courts across the country” and citing cases). {65} Many cases have held that this type of statement will usually be non-testimonial, but that the inquiry should be fact-specific and if there are articulable indications that either the declarant or the officer was trying to do more than simply get help or secure the scene, then the statement might be considered testimonial. See, e.g., State v. Parks, 211 Ariz. 19, 116 P.3d 631, 642 (Ariz.Ct.App. 2005) (“[PJolice questioning during a field investigation does not automatically exempt the statements from being testimonial.”); Wright, 701 N.W.2d at 812-13 (<HOLDING>); State v. Allen, 171 N.C.App. 71, 614 S.E.2d
holding that police officers have a duty to conduct an investigation into the basis of the witness report holding that the trial court did not err in precluding crossexamination of police officer as to statements made during an internal police investigation because the purpose for which such testimony was sought was pure speculation which has no support in the record 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 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 the admission of testimonial statements against a defendant is unconstitutional when the declarant does not appear at trial unless the declarant is unavailable and the defendant had a prior opportunity for crossexamination