How have courts interpreted the confrontation clause in a case where a witness has given a spontaneous statement?

Here, as in United States v. Inadi, supra, 475 U.S. at pages ---- - ----, 106 S.Ct. at pages 1126, 1127, 89 L.Ed.2d at pages 398, 399, the victim's spontaneous statements are not a "weaker substitute for live testimony" but a valuable form of evidence "that cannot be replicated, even if the declarant testifies to the same matters in court," and are therefore "usually irreplaceable as substantive evidence," and of great value in furthering the purpose of the confrontation clause to " 'advance the "accuracy of the truth determining process in criminal trials." ' " ²

Page 276