Other cases to the same effect are to be found, and in this country the ruling has been in the same way.

The court wrote that Lord Morley's Case established that if a witness "who had been examined by the Crown, and was then absent, was detained by the means or procurement of the prisoner," "then the examination should be read" into evidence.

—the Georgia Supreme Court focused on the accused's voluntary wrongful conduct that created the witness's unavailability at trial.

—holding that the Sixth Amendment did not prohibit introduction of written testimony from an absent witness because "[t] he practice intended to be prohibited by that provision, was the secret examinations, so much abused during the reign of the Stuarts, and was not intended to disturb any general rule of crim

—and also claimed that an 1856 Georgia case endorsed the application of the forfeiture exception not just to “Marian examinations carrying a confrontation requirement, but coroner' s inquests that lacked one.”

In the particular case, the evidence was not admitted because the state did not prove that the witness was absent by the action of the defendant

In 1856, the Georgia Supreme Court explained that the doctrine of forfeiture by wrongdoing would lead to the admission of a witness's examination before the committing magistrate.

I concede this in part because of the evolving consensus80 around the issue and in part because the explanation can be found in at least one 19th century case

[CITATION] FORFEITURE BY WRONGDOING: ASurvey AND AN ARGUMENT