WI: Confrontation clause does not apply to suppression hearings

The confrontation clause is a trial right, so does not apply to suppression hearings. So the use of a deceased police officer’s recorded statement at a suppression hearing did not violate the confrontation clause. State v. Zamzow, 2017 WI 29, 2017 Wisc. LEXIS 168 (April 6, 2017), aff’g 2016 WI App 7, 366 Wis. 2d 562, 874 N.W.2d 328 (2015) (see Treatise § 60.51 n. 2,5)

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