taint hearing (Pennsylvania) · Go Syfert
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taint hearing in Pennsylvania

30 Pennsylvania opinions name it 4 courts 1976–2026 6 in the last five years

The cases below were cited by Pennsylvania 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 (7)

CaseFollowedCited
Commonwealth v. Delbridgegreen
pa · 2003 · cited in 9 Pennsylvania opinions naming this issue, 2009–2025
2 sentences

2025Id. at 40 . -6- J-S08022-25 The Court in Delbridge set the parameters for trial courts to follow for a taint hearing.

2025In a taint hearing, it is within the trial court’s discretion to decide whether, based on the facts of a case, “expert testimony would assist the court in understanding the evidence or determining a fact in issue.” Id. at 43 (citing Pa.R.E. 702).

49
Commonwealth v. Mooregreen
pasuperct · 2009 · cited in 6 Pennsylvania opinions naming this issue, 2011–2026
2 sentences

2026In Commonwealth v. Moore, 980 A.2d 647 (Pa.Super. 2009), this Court reiterated that the critical age for purposes of conducting a taint hearing is not the age at the time of the crime but the age at the time of trial.

2019In Commonwealth v. Moore, 980 A.2d 647 (Pa.Super.2009), this Court reiterated that the critical age for purposes of conducting a taint hearing is not the age at the time of the crime but the age at the time of trial.

46
United States v. Wadegreen
scotus · 1967 · cited in 2 Pennsylvania opinions naming this issue, 2019–2019
2 sentences

2019See Wade , 388 U.S. at 241 , 87 S.Ct. 1926 ; Gilbert , 388 U.S. at 272-73 , 87 S.Ct. 1951 .

2019See Wade , 388 U.S. at 241 , 87 S.Ct. 1926 ; Gilbert , 388 U.S. at 272-73 , 87 S.Ct. 1951 .

22
Commonwealth v. Juddgreen
pasuperct · 2006 · cited in 4 Pennsylvania opinions naming this issue, 2016–2018
2 sentences

2017During the hearing the party alleging taint bears the burden of production of evidence of taint and the burden of persuasion to show taint by clear and convincing evidence.” Id. at 40 . “[T]he resolution of a taint challenge to the competency of a child witness is a matter addressed to the discretion of the trial court.” Id. at 41 . 28 “When determining whether a defendant has presented ‘some evidence’ of taint, the court must consider the totality of the circumstances surrounding the child’s allegations.” Judd, 897 A.2d at 1229 .

2016See Commonwealth v. Pena, 31 A.3d 704, 707 (Pa. Super. 2011) (stating that because witnesses were “fourteen and fifteen at the time of the taint hearing -7- J-S06026-16 … the issue of taint was totally irrelevant as a matter of law[]”); accord Commonwealth v. Judd, 897 A.2d 1224, 1229 (Pa. Super. 2006), appeal denied, 912 A.2d 1291 (Pa. 2006).

14
Commonwealth v. Penagreen
pasuperct · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2013–2016
2 sentences

2016See Commonwealth v. Pena, 31 A.3d 704, 707 (Pa. Super. 2011) (stating that because witnesses were “fourteen and fifteen at the time of the taint hearing -7- J-S06026-16 … the issue of taint was totally irrelevant as a matter of law[]”); accord Commonwealth v. Judd, 897 A.2d 1224, 1229 (Pa. Super. 2006), appeal denied, 912 A.2d 1291 (Pa. 2006).

2016See Commonwealth v. Pena, 31 A.3d 704, 707 (Pa. Super. 2011) (stating that because witnesses were “fourteen and fifteen at the time of the taint hearing -7- J-S06026-16 … the issue of taint was totally irrelevant as a matter of law[]”); accord Commonwealth v. Judd, 897 A.2d 1224, 1229 (Pa. Super. 2006), appeal denied, 912 A.2d 1291 (Pa. 2006).

12
Commonwealth v. Smithgreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Commonwealth v. Smith, 167 A.3d 782, 790 (Pa. Super. 2017). -7- J-S71029-19 Here, the trial court explained its decision to deny Appellant’s request for a taint hearing as follows: In this case, applying the Delbridge factors, this [c]ourt denied the defense request for a taint hearing because the defense offer of proof was insufficient and did not meet the threshold that would entitle him to a taint hearing. [N.T., 6/25/18, at 17].

11
Com. v. Juddgreen
pa · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See Commonwealth v. Pena, 31 A.3d 704, 707 (Pa. Super. 2011) (stating that because witnesses were “fourteen and fifteen at the time of the taint hearing -7- J-S06026-16 … the issue of taint was totally irrelevant as a matter of law[]”); accord Commonwealth v. Judd, 897 A.2d 1224, 1229 (Pa. Super. 2006), appeal denied, 912 A.2d 1291 (Pa. 2006).

2016See Commonwealth v. Pena, 31 A.3d 704, 707 (Pa. Super. 2011) (stating that because witnesses were “fourteen and fifteen at the time of the taint hearing -7- J-S06026-16 … the issue of taint was totally irrelevant as a matter of law[]”); accord Commonwealth v. Judd, 897 A.2d 1224, 1229 (Pa. Super. 2006), appeal denied, 912 A.2d 1291 (Pa. 2006).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Poust v. Hyltongreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018But see Poust v. Hylton, 940 A.2d 380, 387 (Pa. Super. 2007) (holding that where counsel used the word “cocaine” in questioning a witness after the mention of cocaine had been precluded in a ruling on a motion in limine, a mistrial was warranted - 12 - J-A11018-18 and “it [was] abundantly clear that no curative instruction could have obliterated the taint of defense counsel’s use of the word”).

11

Also cited on this issue (17)

CaseCitedYears
Gilbert v. California green
scotus · 1967
2 sentences

2019See Wade, 388 U.S. at 241 ; Gilbert, 388 U.S. at 272-73 .

2019See Wade , 388 U.S. at 241 , 87 S.Ct. 1926 ; Gilbert , 388 U.S. at 272-73 , 87 S.Ct. 1951 .

22019–2019
Alleyne v. United States green
· 2013
1 sentence

2026Anzalone filed a pro se response to the Rule 907 notice alleging that PCRA counsel failed to raise trial counsel’s ineffectiveness for: (1) failure to request a taint hearing to test the validity of the minor victims’ testimony and (2) failure to raise a challenge to the imposition of mandatory minimum sentences pursuant to Alleyne v. United States, 570 U.S. 99 (2013).

12026–2026
Commonwealth v. Finley green
pa · 1988
2 sentences

2025On December 3, 2020, the trial court reinstated Appellant’s right to file a petition for allowance of appeal nunc pro tunc and Appellant subsequently filed the petition on December 29, 2020. 3 Commonwealth v. Turner, 518 Pa. 491 , 544 A.2d 927 (1988); Commonwealth v. Finley, 550 A.2d 213 (Pa.Super. 1988) (en banc). -5- J-S07041-25 Appellant raises the following issue for our review: Trial counsel was ineffective due to failure to bring in a taint analysis of the forensic interview by failing to request a taint hearing.

2025On December 3, 2020, the trial court reinstated Appellant’s right to file a petition for allowance of appeal nunc pro tunc and Appellant subsequently filed the petition on December 29, 2020. 3 Commonwealth v. Turner, 518 Pa. 491 , 544 A.2d 927 (1988); Commonwealth v. Finley, 550 A.2d 213 (Pa.Super. 1988) (en banc). -5- J-S07041-25 Appellant raises the following issue for our review: Trial counsel was ineffective due to failure to bring in a taint analysis of the forensic interview by failing to request a taint hearing.

12025–2025
Commonwealth v. Turner green
pa · 1988
2 sentences

2025On December 3, 2020, the trial court reinstated Appellant’s right to file a petition for allowance of appeal nunc pro tunc and Appellant subsequently filed the petition on December 29, 2020. 3 Commonwealth v. Turner, 518 Pa. 491 , 544 A.2d 927 (1988); Commonwealth v. Finley, 550 A.2d 213 (Pa.Super. 1988) (en banc). -5- J-S07041-25 Appellant raises the following issue for our review: Trial counsel was ineffective due to failure to bring in a taint analysis of the forensic interview by failing to request a taint hearing.

2025On December 3, 2020, the trial court reinstated Appellant’s right to file a petition for allowance of appeal nunc pro tunc and Appellant subsequently filed the petition on December 29, 2020. 3 Commonwealth v. Turner, 518 Pa. 491 , 544 A.2d 927 (1988); Commonwealth v. Finley, 550 A.2d 213 (Pa.Super. 1988) (en banc). -5- J-S07041-25 Appellant raises the following issue for our review: Trial counsel was ineffective due to failure to bring in a taint analysis of the forensic interview by failing to request a taint hearing.

12025–2025
Commonwealth v. Spotz green
pa · 2011
1 sentence

2024He contends that the taint hearing was necessary because his defense was that his wife and mother-in- law “turned his children against him” due to his former homosexuality and problems with substance abuse, but that “[n]one of these influences were examined by trial counsel.” Id.

12024–2024
Commonwealth v. Davis green
pasuperct · 2007
1 sentence

2023Id. at 910 .

12023–2023
Com. v. Saez, R. green
pasuperct · 2019
1 sentence

2021Id.

12021–2021
Commonwealth v. Mazzoccoli green
pa · 1977
1 sentence

2019Johns claims that such a hearing was appropriate because the police interviewed K.A.P. without his parents present and the same police officer who interviewed K.A.P. also drove him to court on the day ____________________________________________ 7 Johns’ reliance on Commonwealth v. Mazzaccoli, 380 A.2d 786 (Pa. 1977), is inapposite.

12019–2019
Commonwealth v. Cannon green
pa · 1989
1 sentence

2018Here, while we agree with Appellant that a motion in limine is designed to prevent prejudicial information from reaching the jury, we agree with the trial court that Appellant’s statement that the legal aspects of his termination from Geisinger were “muddled” opened the door to permit the jury to hear the outcome of the Geisinger litigation.5 See Cannon, 563 A.2d at 922-23 .

12018–2018
Commonwealth v. Cesar green
pasuperct · 2006
1 sentence

2007The appellant in that case argued that the witness had been “improperly coached by her mother, the assistant District Attorney, and the victim/witness coordinator.” Cesar, supra at 985 .

12007–2007
Commonwealth v. Hill green
pa · 1999
2 sentences

2005See Pa.R.Crim.P. 600(C)(3), which excludes from the commencement period: “such period of delay at any stage of the proceedings as results from: (a) the unavailability of the defendant or the defendant’s attorney; (b) any continuance granted at the request of the defendant or the defendant’s attorney.” See also, Commonwealth v. Hill, 558 Pa. 238 , 736 A.2d 578 (1999) (Time between filing and resolution of defendant’s pretrial motions is excludable from the speedy trial period if the motion delayed trial and thus made the defendant unavailable).

2005See Pa.R.Crim.P. 600(C)(3), which excludes from the commencement period: “such period of delay at any stage of the proceedings as results from: (a) the unavailability of the defendant or the defendant’s attorney; (b) any continuance granted at the request of the defendant or the defendant’s attorney.” See also, Commonwealth v. Hill, 558 Pa. 238 , 736 A.2d 578 (1999) (Time between filing and resolution of defendant’s pretrial motions is excludable from the speedy trial period if the motion delayed trial and thus made the defendant unavailable).

12005–2005
English v. State green
wyo · 1999
2 sentences

2003Id.

2003Id.

12003–2003
Delaware v. Prouse green
scotus · 1979
1 sentence

1985In Delaware v. Prouse, 440 U.S. 648 (1979), the Supreme Court of the United States said that what •makes unconstitutional the stopping of a vehicle for a license check is the unconstrained exercise of discretion by a police officer in stopping the vehicle.

11985–1985
Middleberg v. Middleberg green
pa · 1967
2 sentences

1977Commonwealth v. Ray, 448 Pa. 307 , 292 A.2d 410 (1972); Middleberg v. Middleberg, 427 Pa. 114 , 233 A.2d 889 (1967); Commonwealth v. Guardiani, 226 Pa.Super. 435 , 310 A.2d 422 (1973).

1977Commonwealth v. Ray, 448 Pa. 307 , 292 A.2d 410 (1972); Middleberg v. Middleberg, 427 Pa. 114 , 233 A.2d 889 (1967); Commonwealth v. Guardiani, 226 Pa.Super. 435 , 310 A.2d 422 (1973).

11977–1977
Commonwealth v. Ray green
pa · 1972
2 sentences

1977Commonwealth v. Ray, 448 Pa. 307 , 292 A.2d 410 (1972); Middleberg v. Middleberg, 427 Pa. 114 , 233 A.2d 889 (1967); Commonwealth v. Guardiani, 226 Pa.Super. 435 , 310 A.2d 422 (1973).

1977Commonwealth v. Ray, 448 Pa. 307 , 292 A.2d 410 (1972); Middleberg v. Middleberg, 427 Pa. 114 , 233 A.2d 889 (1967); Commonwealth v. Guardiani, 226 Pa.Super. 435 , 310 A.2d 422 (1973).

11977–1977
Commonwealth v. Guardiani green
pasuperct · 1973
2 sentences

1977Commonwealth v. Ray, 448 Pa. 307 , 292 A.2d 410 (1972); Middleberg v. Middleberg, 427 Pa. 114 , 233 A.2d 889 (1967); Commonwealth v. Guardiani, 226 Pa.Super. 435 , 310 A.2d 422 (1973).

1977Commonwealth v. Ray, 448 Pa. 307 , 292 A.2d 410 (1972); Middleberg v. Middleberg, 427 Pa. 114 , 233 A.2d 889 (1967); Commonwealth v. Guardiani, 226 Pa.Super. 435 , 310 A.2d 422 (1973).

11977–1977
Commonwealth v. Garvin green
pa · 1972
2 sentences

1976Wong Sun, supra; Commonwealth v. Garvin, 448 Pa. 258 , 293 A.2d 33 (1972); 4 see also, Belsky, Criminal Procedure in Pennsylvania: The Pretrial Issues in Four Parts, Part III, 78 Dick.L.Rev. 209, 262 (1973).

1976Wong Sun, supra; Commonwealth v. Garvin, 448 Pa. 258 , 293 A.2d 33 (1972); 4 see also, Belsky, Criminal Procedure in Pennsylvania: The Pretrial Issues in Four Parts, Part III, 78 Dick.L.Rev. 209, 262 (1973).

11976–1976

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 3121 (7) PA § 18 Pa. Cons. Stat. § 3125 (4)

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 79 (1938–2026) PA 30 (1976–2026) KS 12 (1905–2019) MI 10 (1976–2015) WY 10 (1999–2022) NY 10 (1964–2025) NJ 9 (1985–2026) MD 7 (1979–2020) IL 4 (1965–1980) OR 4 (2008–2021) NM 3 (1984–2011) MO 3 (1902–1996) MN 2 (2004–2026) CA 2 (2007–2016) OH 2 (2024–2024) CO 2 (1979–2005) AR 2 (1988–2003)

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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