L.Ed.2d 597 (1980), which held that the Sixth Amendment did not bar admission of hearsay if the statement bore “adequate indicia of reliability,” i.e., if the statement fell within a firmly-rooted hearsay exception or there was “a showing of particularized guarantees of trustworthiness.” In Crawford, the Supreme Court receded from Roberts where the evidence at issue is a testimonial statement, holding that “[w]here testimonial statements are at issue, the only indicium of reliability sufficient to satisfy constitutional demands is the one the Constitution actually prescribes: confrontation.” 541 U.S. at 68-69, 124 S.Ct. 1354 (emphasis added). Following Crawford, the introduction of out-of-court testimonial statements violates the Sixth Amendment, regardless of any rule of eviden 2006) (<HOLDING>). Applying these principles to the instant
holding that driving record is nontestimonial as it is not accusatory and does not describe specific criminal wrongdoing of the defendant it contains no expression of opinion or conclusion requiring the exercise of discretion and it merely represents the objective result of a public records search holding that driving records were nontestimonial holding that it is not holding that a certified abstract of a defendants driving record was nontestimonial holding that the plaintiffs speech was not a matter of public concern because it did not bring to light actual or potential wrongdoing or breach of public trust on the part of the defendant and others