In a case decided yesterday by the United States Supreme Court, Davis v. Washington, Justice Scalia cited to the Second Circuit decision in the Martha Stewart case for the point, "[t]he solemnity of even an oral declaration of relevant past fact to an investigating officer is well enough established by the severe consequences that can attend a deliberate falsehood."   Which case does this cite fit into – the 911 Crawford case.

(esp) (w/ a hat tip to Kathryn Kase)