Crawford v. Commonwealth, 281 Va. 84 (2011)
Sarah Crawford left an abusive relationship with her husband, Anthony Dale Crawford. She remained fearful of him and took various precautions to protect herself, including applying for an order of protection. She signed an affidavit for the order, in which she recounted instances of past abuse, including threats to her life. The following month, she was found murdered and evidence overwhelmingly pointed to her estranged husband. Before the trial, Anthony made a motion to suppress the affidavit, arguing that the document was testimonial hearsay.