that the Confrontation Clause bars the “admission of testimonial statements of a witness who did not appear at trial unless he was unavailable to testify, and the defendant had had a prior opportunity for cross-examination.” Id. at 53-54, 124 S.Ct. 1354. The Confrontation Clause was thus deemed to guarantee the opportunity for cross-examination as the procedural mechanism for testing the reliability of evidence: To be sure, the Clause’s ultimate goal is to ensure reliability of evidence, but it is a procedural rather than a substantive guarantee. It commands, not that evidence be reliable, but that reliability be assessed in a particular manner: by testing in the crucible of cross-examination. Id. at 61, 124 S.Ct. 1354; see also State v. Gorman, 2004 ME 90, ¶ 46, 854 A.2d 1164, 1175 (<HOLDING>). [¶ 12] Crawford treated “testimony” as being
holding coconspirator hearsay exception does not violate confrontation clause holding that statements within a firmly rooted hearsay exception do not violate the confrontation clause holding that the confrontation clause applies only to testimonial hearsay holding that hearsay objection does not preserve a confrontation clause challenge recognizing that statements admissible under an exception to the hearsay rule may be inadmissible when tested against the confrontation clause  because confrontation clause analysis differs from hearsay rule analysis