totality of the circumstances test (Missouri) · Go Syfert
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totality of the circumstances test in Missouri

38 Missouri opinions name it 2 courts 1966–2025 4 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (24)

CaseFollowedCited
State v. Higginsgreen
mo · 1979 · cited in 3 Missouri opinions naming this issue, 1983–1988
2 sentences

1988See Higgins, 592 S.W.2d at 160 .

1987See Higgins, 592 S.W.2d at 160 .

33
State v. Schnellegreen
moctapp · 1996 · cited in 2 Missouri opinions naming this issue, 2003–2003
2 sentences

2003State v. Schnelle, 924 S.W.2d 292, 296 (Mo.App. 1996).

2003State v. Schnelle, 924 S.W.2d 292, 296 (Mo.App.1996).

22
Davis v. North Carolinagreen
scotus · 1966 · cited in 2 Missouri opinions naming this issue, 1966–1968
2 sentences

1968The duration and nature of incommunicado custody, the presence or absence of advice concerning the defendant’s constitutional rights, and the granting or refusal of requests to communicate with lawyers, relatives or friends have all been rightly regarded as important data bearing on the basic inquiry.’ (Dissenting opinion of Justice White in Miranda v. State of Arizona; see also dissenting opinion of Justice Clark therein; see also Davis v. State of North Carolina, October Term 1965, 384 U.S. 737 , 86 S.Ct. 1761 , 16 L.Ed.2d 895 .) We do not understand that Escobedo changed the totality of the

1968The duration and nature of incommunicado custody, the presence or absence of advice concerning the defendant’s constitutional rights, and the granting or refusal of requests to communicate with lawyers, relatives or friends have all been rightly regarded as important data bearing on the basic inquiry.’ (Dissenting opinion of Justice White in Miranda v. State of Arizona; see also dissenting opinion of Justice Clark therein; see also Davis v. State of North Carolina, October Term 1965, 384 U.S. 737 , 86 S.Ct. 1761 , 16 L.Ed.2d 895 .) We do not understand that Escobedo changed the totality of the

22
Illinois v. Gatesgreen
scotus · 1983 · cited in 9 Missouri opinions naming this issue, 1987–2015
2 sentences

2013“Under the totality of the circumstances test, a deficiency in one area can be compensated for by a strong showing of another or by ‘some other indicia of reliability.’” Ford, 21 S.W.3d at 35 (quoting Gates, 462 U.S. at 233 , 103 S.Ct. 2317 ).

2013“Under the totality of the circumstances test, a deficiency in one area can be compensated for by a strong showing of another or by ‘some other indicia of reliability.’” Ford, 21 S.W.3d at 35 (quoting Gates, 462 U.S. at 233 , 103 S.Ct. 2317 ).

19
State v. Fordgreen
moctapp · 2000 · cited in 2 Missouri opinions naming this issue, 2013–2017
2 sentences

2017“Under the totality of the circumstances test, a deficiency in one area can be compensated for by a strong showing of another or by some other indicia of reliability.” Id. at 34 (internal quotation omitted).

2013“Under the totality of the circumstances test, a deficiency in one area can be compensated for by a strong showing of another or by ‘some other indicia of reliability.’” Ford, 21 S.W.3d at 35 (quoting Gates, 462 U.S. at 233 , 103 S.Ct. 2317 ).

12
State v. Penningtongreen
mo · 1982 · cited in 2 Missouri opinions naming this issue, 1987–1991
2 sentences

1991In State v. Pennington, 642 S.W.2d 646 (Mo.1982), our supreme court reiterated several well-established principles governing the determination of probable cause to issue a search warrant.

1987While the review for a “substantial basis” of probable cause under the totality of the circumstances test contemplates great deference to the magistrate’s decision, State v. Pennington, 642 S.W.2d 646, 648 (Mo.1982), the magistrate is not allowed unfettered discretion.

12
State v. Lanegreen
moctapp · 2013 · cited in 1 Missouri opinions naming this issue, 2025–2025
1 sentence

2025Yet, when applying the totality of the circumstances test, “the only evidence to be considered is that adduced at the [Chapter 491] hearing.” State v. Sprinkle, 122 S.W.3d 652, 661 (Mo. App. W.D. 2003); see also State v. Lane, 415 S.W.3d 740, 751 (Mo. App. S.D. 2013) (holding “[t]his observation is consistent with the express language used in section 491.075.1(1), that the out-of-court statements are admissible if ‘[t]he court finds, in a hearing conducted outside the presence of the jury that the time, content and circumstances of the 10 statement provide sufficient indicia of reliability [.]

11
State v. Sprinklegreen
moctapp · 2003 · cited in 1 Missouri opinions naming this issue, 2025–2025
1 sentence

2025Yet, when applying the totality of the circumstances test, “the only evidence to be considered is that adduced at the [Chapter 491] hearing.” State v. Sprinkle, 122 S.W.3d 652, 661 (Mo. App. W.D. 2003); see also State v. Lane, 415 S.W.3d 740, 751 (Mo. App. S.D. 2013) (holding “[t]his observation is consistent with the express language used in section 491.075.1(1), that the out-of-court statements are admissible if ‘[t]he court finds, in a hearing conducted outside the presence of the jury that the time, content and circumstances of the 10 statement provide sufficient indicia of reliability [.]

11
Hallquist v. Middengreen
moctapp · 2006 · cited in 1 Missouri opinions naming this issue, 2025–2025
2 sentences

2025“Another public policy consideration is whether a defendant has ‘some right or obligation to control the activity that presents the danger of injury.’” Id. at 436 (quoting Burrell ex rel.

2025Totality of the Circumstances Even under the totality of the circumstances test, Defendants do not owe Plaintiffs a duty to protect them from the negligent incursion of a third party (1) under a foreseeability analysis and (2) because public policy does not support imposing a duty under these facts. “[W]hether a duty exists in a particular case depends on several public policy considerations including ‘the foreseeability of the injury, the likelihood of the injury, the magnitude of the burden of guarding against it and the consequences of placing that burden on defendant.’” Scales, 615 S.W.3d

11
State v. Morgangreen
moctapp · 2012 · cited in 1 Missouri opinions naming this issue, 2021–2021
1 sentence

2021Id. at 430-31 ; State v. Morgan, 366 S.W.3d 565, 576-77 (Mo. App. E.D. 2012).

11
State v. Kuhngreen
moctapp · 2003 · cited in 1 Missouri opinions naming this issue, 2005–2005
1 sentence

2005This totality of the circumstances test was followed in State v. Kuhn, where the court *279 found that bringing a child to a home containing wow-dangerous chemicals did not present substantial risk, although the chemicals included some of the materials needed to make methamphetamine. 115 S.W.3d 845, 849-50 (Mo.App.2003).

11
Delta Tau Delta, Beta Alpha Chapter v. Johnsongreen
ind · 1999 · cited in 1 Missouri opinions naming this issue, 2002–2002
1 sentence

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

11
Clohesy v. Food Circus Supermarkets, Inc.green
nj · 1997 · cited in 1 Missouri opinions naming this issue, 2002–2002
2 sentences

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

11
Hills v. Bridgeview Little League Ass'ngreen
ill · 2000 · cited in 1 Missouri opinions naming this issue, 2002–2002
2 sentences

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

11
Lechmanski v. Marine Midland Bankgreen
nyappdiv · 1999 · cited in 1 Missouri opinions naming this issue, 2002–2002
2 sentences

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

11
Ellis v. Luxbury Hotels, Inc.green
ind · 1999 · cited in 1 Missouri opinions naming this issue, 2002–2002
2 sentences

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

2002“The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider.” Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). “[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to ‘all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a criminal act was foreseeable.’ ” Ellis v. Lwcbury Hotels, Inc., 716 N.E.2d 359, 360-61 (Ind.1999) (quoting Delta Ta

11
State v. Redmangreen
mo · 1996 · cited in 1 Missouri opinions naming this issue, 1996–1996
11
State v. Gardnergreen
mo · 1987 · cited in 1 Missouri opinions naming this issue, 1991–1991
11
Abdullah v. Arkansasgreen
scotus · 1988 · cited in 1 Missouri opinions naming this issue, 1991–1991
11
Grays v. Hughesgreen
scotus · 1988 · cited in 1 Missouri opinions naming this issue, 1991–1991
11
State v. Wrightgreen
mo · 1974 · cited in 1 Missouri opinions naming this issue, 1985–1985
11
Jones v. United Statesred
scotus · 1960 · cited in 1 Missouri opinions naming this issue, 1983–1983
11
State v. Dodsongreen
mo · 1973 · cited in 1 Missouri opinions naming this issue, 1978–1978
11
State v. Williamsgreen
mo · 1970 · cited in 1 Missouri opinions naming this issue, 1978–1978
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (23)

CaseCitedYears
In Re SM green
moctapp · 1997
2 sentences

2002However, in In re S.M., this court, after discussing the various approaches used in other jurisdictions, adopted the totality of the circumstances test for deciding what constitutes a temporary absence under § 452.445(4). 938 S.W.2d at 918 .

2000"In comparing the different approaches to resolving the temporary absence issue, the totality of the circumstances test is best suited to adequately deal with the variety of situations which occur....” Id. at 918 . 12 .

22000–2002
Neil v. Biggers green
scotus · 1972
2 sentences

1988Moreover, George’s in-court identification of defendant was reliable under the totality of the circumstances test of Neil v. Biggers, 409 U.S. 188 , 93 S.Ct. 375 , 34 L.Ed.2d 401 (1972).

1988Moreover, George’s in-court identification of defendant was reliable under the totality of the circumstances test of Neil v. Biggers, 409 U.S. 188 , 93 S.Ct. 375 , 34 L.Ed.2d 401 (1972).

21987–1988
Miranda v. Arizona green
scotus · 1966
2 sentences

1968For trials after June 13, 1966, Miranda v. State of Arizona, October Term 1965, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 , imposes new and different rules.

1968For trials after June 13, 1966, Miranda v. State of Arizona, October Term 1965, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 , imposes new and different rules.

21966–1968
State of Missouri, Plaintiff/Respondent v. Rickey Bates green
moctapp · 2015
2 sentences

2023Id. (citing Bates, 464 S.W.3d at 263 ).

2023Id. (citing Bates, 464 S.W.3d at 263 ).

12023–2023
State v. Rodriguez green
utah · 2007
1 sentence

2012Id. at 782 .

12012–2012
In the Interest of N.J.K. v. Juvenile Officer green
moctapp · 2004
1 sentence

2011N.J.K., 139 S.W.3d at 256 .

12011–2011
State v. Burrell green
mo · 2005
1 sentence

2005Burrell, 160 S.W.3d at 802 .

12005–2005
State v. Porras green
moctapp · 2002
1 sentence

2003Porras, 84 S.W.3d at 157 .

12003–2003
Madden v. C & K Barbecue Carryout, Inc. green
mo · 1988
2 sentences

2002But see Timothy A. Reuschel, Here's Your Burrito and Watch Your Back: Does Missouri Really Want to Hold Businesses Liable for Attacks on Patrons?, 65 Mo. L.Rev. 255, 258 (2000) ("In Madden , the court did not explicitly adopt the `totality of the circumstances' test or the `prior similar incidents' test for foreseeability.") Although Madden considered prior similar incidents, it used language implying a totality of the circumstances test ("the facts and circumstances of a given case") Madden, 758 S.W.2d at 62 .

2002But see Timothy A. Reuschel, Here’s Your Burrito and Watch Your Back: Does Missouri Really Want to Hold Businesses Liable for Attacks on Patrons?, 65 Mo. L.Rev. 255, 258 (2000) (“In Madden , the court did not explicitly adopt the ‘totality of the circumstances’ test or the ‘prior similar incidents’ test for foreseeability.”) Although Madden considered prior similar incidents, it used language implying a totality of the circumstances test (“the facts and circumstances of a given case”) Madden, 758 S.W.2d at 62 .

12002–2002
McClung v. Delta Square Ltd. Partnership green
tenn · 1996
2 sentences

2002To the extent the concurrence is saying those facts and circumstances cannot be considered, we disagree. [13] "The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider." Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). "[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to `all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a crimi

2002“The totality of the circumstances standard encompasses all the factors a reasonably prudent person would consider.” Clohesy v. Food Circus Supermarkets, Inc., 149 N.J. 496 , 694 A.2d 1017, 1023 (1997). “[I]n determining whether the totality of the circumstances supports the imposition of a duty, a court must look to ‘all of the circumstances surrounding an event, including the nature, condition, and location of the land, as well as prior similar incidents, to determine whether a criminal act was foreseeable.’ ” Ellis v. Lwcbury Hotels, Inc., 716 N.E.2d 359, 360-61 (Ind.1999) (quoting Delta Ta

12002–2002
State v. Kelley green
moctapp · 1997
1 sentence

1999“In determining whether a child’s out-of-court statements possess ‘sufficient indicia of reliability’ for the purposes of Sec. 491.075, Missouri courts have adopted a totality of the circumstances test that includes the consideration of several, non-ex- elusive factors which include (1) spontaneity and consistent repetition; (2) the mental state of the declarant; and (3) the lack of a motive to fabricate.” Kelley, 945 S.W.2d at 614 .

11999–1999
United States v. Miller green
ca8 · 1994
11997–1997
Florida v. Royer green
scotus · 1983
2 sentences

1997Stevens, 845 S.W.2d at 129 ; Florida v. Royer, 460 U.S. 491 , 493 n. 2, 103 S.Ct. 1819 , 1321 n. 2, 75 L.Ed.2d 229 , 233 n. 2 (1983).

1997Stevens, 845 S.W.2d at 129 ; Florida v. Royer, 460 U.S. 491 , 493 n. 2, 103 S.Ct. 1819 , 1321 n. 2, 75 L.Ed.2d 229 , 233 n. 2 (1983).

11997–1997
State v. Worrel green
moctapp · 1996
11997–1997
United States v. Sokolow green
scotus · 1989
2 sentences

1997Id.; Sokolow, 490 U.S. at 9-10 , 109 S.Ct. at 1586-87 , 104 L.Ed.2d at 11-12 . “[T]he relevant inquiry is not whether the particular conduct is ‘innocent’ or ‘guilty,’ but the degree of suspicion that attaches to particular types of nonerimi-nal acts.” Sokolow, 490 U.S. at 10 , 109 S.Ct. at 1587 , 104 L.Ed.2d at 12 (quoting Illinois v. Gates, 462 U.S. 213, 238 , 103 S.Ct. 2317, 2332 , 76 L.Ed.2d 527, 548 (1983)).

1997Id.; Sokolow, 490 U.S. at 9-10 , 109 S.Ct. at 1586-87 , 104 L.Ed.2d at 11-12 . “[T]he relevant inquiry is not whether the particular conduct is ‘innocent’ or ‘guilty,’ but the degree of suspicion that attaches to particular types of nonerimi-nal acts.” Sokolow, 490 U.S. at 10 , 109 S.Ct. at 1587 , 104 L.Ed.2d at 12 (quoting Illinois v. Gates, 462 U.S. 213, 238 , 103 S.Ct. 2317, 2332 , 76 L.Ed.2d 527, 548 (1983)).

11997–1997
State v. Stevens green
moctapp · 1993
1 sentence

1997Stevens, 845 S.W.2d at 129 ; Florida v. Royer, 460 U.S. 491 , 493 n. 2, 103 S.Ct. 1819 , 1321 n. 2, 75 L.Ed.2d 229 , 233 n. 2 (1983).

11997–1997
Idaho v. Wright green
scotus · 1990
11996–1996
State v. Horsey green
moctapp · 1984
11987–1987
New York Times Co. v. Sullivan green
scotus · 1964
11987–1987
State v. Tolliver green
moctapp · 1977
11985–1985
In Interest of ADR green
mo · 1980
11985–1985
State v. White green
moctapp · 1973
11980–1980
In Re KWB green
moctapp · 1973
11980–1980

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 491.075 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 630 (1972–2026) OH 373 (1984–2026) TX 296 (1971–2026) IL 179 (1974–2026) NC 174 (1978–2026) NJ 166 (1983–2026) CA 147 (1977–2026) TN 133 (1971–2026) LA 106 (1978–2025) MN 99 (1983–2025) GA 96 (1976–2026) WA 93 (1982–2026) AL 90 (1977–2025) CO 89 (1981–2026) FL 89 (1981–2025) WI 88 (1973–2026) ID 77 (1979–2026) MD 77 (1975–2026) KS 75 (1976–2026) VA 74 (1986–2026) CT 68 (1982–2026) MI 68 (1970–2026) MS 57 (1985–2026) ND 57 (1988–2023) IN 52 (1983–2026) UT 48 (1980–2026) IA 46 (1970–2025) MT 43 (1984–2024) AR 41 (1983–2024) NE 40 (1983–2026) ME 40 (1979–2022) MO 38 (1966–2025) DE 34 (1978–2026) NM 33 (1990–2026) MA 33 (1983–2026) NH 32 (1980–2023) AZ 32 (1982–2023) SC 32 (1985–2023) HI 32 (1994–2025) KY 30 (1999–2026) DC 27 (1976–2026) RI 26 (1984–2026) SD 25 (1980–2019) NY 23 (1981–2025) VT 22 (1987–2023) OR 18 (1982–2026) NV 17 (1986–2026) WY 11 (1988–2022) WV 11 (1978–2021) OK 8 (1979–2021) AK 6 (1987–2019) VI 3 (2009–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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