reliability test (Minnesota) · Go Syfert
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reliability test in Minnesota

30 Minnesota opinions name it 2 courts 1977–2019 0 in the last five years

The cases below were cited by Minnesota 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 (17)

CaseFollowedCited
State v. Dillegreen
minn · 1977 · cited in 3 Minnesota opinions naming this issue, 1994–2015
2 sentences

2015Under this prong, the proponent must show that the testing procedures have not introduced "contaminants” that would have "adversely affected the reliability of the test.” State v. Dille, 258 N.W.2d 565, 568 (Minn.1977).

2015State v. Dille, 258 N.W.2d 565, 567 (Minn. 1977).

23
State, Department of Public Safety v. Habischgreen
minn · 1981 · cited in 2 Minnesota opinions naming this issue, 1986–1986
2 sentences

1986See, e.g., State, Dept. of Public Safety v. Habisch, 313 N.W.2d 13, 16 (Minn.1981).

1986See State, Department of Public Safety v. Habisch, 313 N.W.2d 13, 16 (Minn.1981).

22
Crawford v. Washingtongreen
scotus · 2004 · cited in 5 Minnesota opinions naming this issue, 2004–2019
2 sentences

2019The Supreme Court abandoned the reliability analysis set forth in Roberts , see id. at 67 , 124 S.Ct. 1354 , and returned to the original text of the Confrontation Clause, noting that the clause specifically applies to "witnesses against the accused-in other words, those who bear testimony," id. at 51 , 124 S.Ct. 1354 (internal quotation marks omitted) (citation omitted).

2019The Supreme Court abandoned the reliability analysis set forth in Roberts , see id. at 67 , 124 S.Ct. 1354 , and returned to the original text of the Confrontation Clause, noting that the clause specifically applies to "witnesses against the accused-in other words, those who bear testimony," id. at 51 , 124 S.Ct. 1354 (internal quotation marks omitted) (citation omitted).

15
State v. Palmergreen
minnctapp · 1986 · cited in 2 Minnesota opinions naming this issue, 1991–2010
2 sentences

2010Id. at 859 .

1991However, even where a defendant offers evidence contradictory to the state’s evidence, “the weight and credibility of disputed evidence are for the jury.” State v. Boyum, 293 Minn. 482, 482 , 197 N.W.2d 218, 219 (1972); see State v. Palmer, 391 N.W.2d 857, 860 (Minn.App.1986) (relying on blood tests performed with expired test kit and on sample drawn ten months before test).

12
White v. Illinoisgreen
scotus · 1992 · cited in 2 Minnesota opinions naming this issue, 1999–2006
2 sentences

2006State v. Johnson, 679 N.W.2d 169, 174 (Minn.App.2004); see also White, 502 U.S. at 355 n. 8, 112 S.Ct. at 742 n. 8.

2006State v. Johnson, 679 N.W.2d 169, 174 (Minn.App.2004); see also White, 502 U.S. at 355 n. 8, 112 S.Ct. at 742 n. 8.

12
State v. Schwartzgreen
minn · 1989 · cited in 2 Minnesota opinions naming this issue, 2003–2004
2 sentences

2004See generally State v. Schwartz, 447 N.W.2d 422, 424 (Minn.1989) (holding Frye-Mack test applicable to admissibility of DNA testing as a new scientific technique).

2003While Traylor suggests that the scientific community compromised its standards to encourage the manufacturer’s development of a needed product, we have previously recognized the importance of a company’s trade secrets in Schwartz , when we stated that "[a]rguably, trade secrets may be at stake for the commercial laboratories” and "[p]rotective measures could be pursued * * * before denial of discovery is appropriate.” 447 N.W.2d at 427 .

12
Phillip Anthony Roberts v. State of Minnesotagreen
minnctapp · 2014 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016See id.

11
Hounsell v. Commissioner of Public Safetygreen
minnctapp · 1987 · cited in 1 Minnesota opinions naming this issue, 2012–2012
1 sentence

2012“Although the reliability of the testing method and results is a foundational question to be decided by the court in determining admissibility, once admitted into evidence, the reliability of the test is also an issue for the jury in determining the weight to be given to the evidence.” CRIMJIG 29.10 (citations omitted); see also Hounsell, 401 N.W.2d. at 96 (clarifying that because defendant did not object to admission of test results, his challenge is to “the weight to be accorded those results”)..

11
State v. Moua Hergreen
minn · 2008 · cited in 1 Minnesota opinions naming this issue, 2010–2010
1 sentence

2010See Her, 750 N.W.2d at 275 (listing factors to consider under Minn. R.

11
State v. Davisgreen
minnctapp · 1986 · cited in 1 Minnesota opinions naming this issue, 2009–2009
1 sentence

2009First, a statement provided in connection with a polygraph examination may be deemed involuntary if a law enforcement officer “misrepresent[ed] the reliability of the test.” Id.; see also State v. Davis, 381 N.W.2d 86, 88 (Minn.App.1986) (affirming district court’s finding that written statement provided after polygraph was involuntary, in part because examiner “attempted to convince [defendant] that the polygraph test is foolproof’).

11
Underdahl v. Commissioner of Public Safetygreen
minn · 2007 · cited in 1 Minnesota opinions naming this issue, 2008–2008
2 sentences

2008See id. at 711 (holding that the implied consent statute permits a challenge to the reliability of the test, and that a declaratory judgment action is not the sole means of challenge).

2008The Underdahl I court addressed the commissioner’s argument that the “presumption of trustworthiness” provided in Minn.Stat. § 634.16 “[took] away the district court’s jurisdiction over challenges to the reliability of individual [Intoxilyzer] breath results.” Underdahl I, 735 N.W.2d at 710 .

11
State v. Johnsongreen
minnctapp · 2004 · cited in 1 Minnesota opinions naming this issue, 2006–2006
1 sentence

2006State v. Johnson, 679 N.W.2d 169, 174 (Minn.App.2004); see also White, 502 U.S. at 355 n. 8, 112 S.Ct. at 742 n. 8.

11
State v. Dukesgreen
minn · 1996 · cited in 1 Minnesota opinions naming this issue, 2004–2004
1 sentence

2004Dukes, 544 N.W.2d at 19 (citation omitted).

11
State v. Hansengreen
minn · 1981 · cited in 1 Minnesota opinions naming this issue, 1997–1997
2 sentences

1997"Statements which are made under oath and subject to cross-examination may be sufficiently reliable to protect the values associated with the confrontation clause." Hansen, 312 N.W.2d at 102 (citations omitted).

1997“Statements which are made under oath and subject to cross-examination may be sufficiently reliable to protect the values associated with the confrontation clause.” Hansen, 312 N.W.2d at 102 (citations omitted).

11
State v. Boyumgreen
minn · 1972 · cited in 1 Minnesota opinions naming this issue, 1991–1991
2 sentences

1991However, even where a defendant offers evidence contradictory to the state’s evidence, “the weight and credibility of disputed evidence are for the jury.” State v. Boyum, 293 Minn. 482, 482 , 197 N.W.2d 218, 219 (1972); see State v. Palmer, 391 N.W.2d 857, 860 (Minn.App.1986) (relying on blood tests performed with expired test kit and on sample drawn ten months before test).

1991However, even where a defendant offers evidence contradictory to the state’s evidence, “the weight and credibility of disputed evidence are for the jury.” State v. Boyum, 293 Minn. 482, 482 , 197 N.W.2d 218, 219 (1972); see State v. Palmer, 391 N.W.2d 857, 860 (Minn.App.1986) (relying on blood tests performed with expired test kit and on sample drawn ten months before test).

11
State v. Burchgreen
minn · 1969 · cited in 1 Minnesota opinions naming this issue, 1986–1986
1 sentence

1986Id. at 552.

11
State v. Elijahgreen
minn · 1940 · cited in 1 Minnesota opinions naming this issue, 1977–1977
2 sentences

1977See, State v. Elijah, 206 Minn. 619 , 289 N.W. 575 (1940).

1977See, State v. Elijah, 206 Minn. 619 , 289 N.W. 575 (1940).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
State v. Jungbauer green
minn · 1984
2 sentences

2009Second, a statement provided in connection with a polygraph examination may be deemed involuntary if a law enforcement officer has “falsely implied] that the results will be admissible in evidence.” Jungbauer, 348 N.W.2d at 346 .

1990As we said in Jungbauer , the result might be different if the evidence indicates the police misrepresented the reliability of the test or falsely implied the results would be admissible in evidence. 348 N.W.2d at 346 .

31990–2009
Thomas Daniel Rhodes v. State of Minnesota, A13-560 green
minn · 2016
1 sentence

2016To satisfy the actual-innocence criterion “the proffered evidence must be unequivocal, intrinsically probable, and free from frailties.” Rhodes, 875 N.W.2d at 788 .

12016–2016
State v. Ostrem green
minn · 1995
1 sentence

2014Specifically, Mosley relies on a five-factor reliability test that we used in Ostrem to analyze a claim that unnecessarily suggestive identification testimony violated the defendant’s due process rights. 4 Ostrem, 535 N.W.2d at 921 .

12014–2014
State v. Hennum green
minn · 1989
1 sentence

2012According to Doe, the Frye-Mack foundational reliability standard only applies when considering whether a specific novel scientific test is reliable, and here, Doe’s evidence is neither novel, scientific, or related to a test. 6 Relying on cases prior to the 2006 amendment, Doe contends that Rule 702 is a helpfulness test, and that the reliability requirement requires only that the theory on which the expert will testify has gone “beyond the experimental stage and has gained a substantial enough scientific acceptance to warrant admissibility.” Hennum, 441 N.W.2d at 798-99 .

12012–2012
Ohio v. Roberts red
scotus · 1980
2 sentences

2009Crawford replaced the reliability standard, first announced in Ohio v. Roberts, 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980), that had allowed admission of the videotape in Danforth’s case.

2009Crawford replaced the reliability standard, first announced in Ohio v. Roberts, 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980), that had allowed admission of the videotape in Danforth’s case.

12009–2009
Danforth v. State green
minn · 2006
2 sentences

2009Crawford, 541 U.S. at 67-68 , 124 S.Ct. 1354 ; Danforth, 718 N.W.2d at 454 .

2009Crawford, 541 U.S. at 67-68 , 124 S.Ct. 1354 ; Danforth, 718 N.W.2d at 454 .

12009–2009

Statutes the citing opinions construe

MN § Minn. Stat. § 609.342 (5) MN § Minn. Stat. § 634.16 (4) MN § Minn. Stat. § 169A.20 (3) MN § Minn. Stat. § 169A.51 (3) MN § Minn. Stat. § 480A.08 (3) MN § Minn. Stat. § 609.223 (3) MN § Minn. Stat. § 634.15 (3)

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

TX 398 (1993–2026) OH 82 (1981–2026) IL 82 (1972–2025) CA 64 (1958–2026) NC 60 (1985–2025) NY 54 (1977–2025) WA 54 (1987–2025) MA 41 (1975–2023) FL 40 (1983–2026) TN 37 (1983–2026) CO 37 (1990–2026) VA 34 (1970–2025) MD 32 (1971–2025) NJ 31 (1987–2024) IN 30 (1969–2020) MN 30 (1977–2019) CT 29 (1977–2025) KS 27 (1978–2025) NM 26 (1975–2025) AL 24 (1980–2016) MI 23 (1980–2026) WI 22 (1980–2025) UT 22 (1994–2025) MS 22 (2001–2020) ID 18 (1984–2026) SC 18 (1993–2024) MO 17 (1978–2021) GA 16 (1982–2025) HI 16 (1996–2021) LA 15 (1979–2026) AZ 14 (1975–2024) DC 13 (1977–2025) IA 13 (1979–2022) PA 12 (1981–2025) WV 12 (1990–2024) NH 11 (1967–2024) DE 11 (1996–2025) MT 10 (1994–2019) OR 8 (1982–2022) AK 6 (1979–1996) OK 6 (1991–2019) NE 6 (1994–2022) ME 6 (1979–2026) WY 6 (1993–2025) SD 6 (1936–2022) AR 4 (1981–2026) VT 4 (2000–2024) KY 4 (2006–2019) VI 4 (1999–2016) RI 3 (1989–1999) NV 2 (2005–2013)

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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