Amicus curiae brief of the National Association of Criminal Defense Lawyers, the Pennsylvania Association of Criminal Defense Lawyers, the Defender Association of Philadelphia, and the Public Defender Association of Pennsylvania in support of the petition for certiorari.

Argument: Statements to child services workers are testimonial in nature. Child services workers are under a legal obligation to submit detailed reports to law enforcement officials when they suspect abuse. This legal obligation, as well as their role in law enforcement investigations, shapes their interviews, even though children are particularly susceptible to suggestion during questioning. Since the primary purpose of child services workers’ investigations is to gather evidence for use in future criminal prosecutions, statements of questionable reliability made to them are testimonial under the Sixth Amendment’s Confrontation Clause.