res gestae exception in Louisiana

177 Louisiana opinions name it 2 courts 1956–2025 5 in the last five years

The cases below were cited by Louisiana 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 (30)

Case	Followed	Cited
State v. Kimblegreen la · 1981 · cited in 42 Louisiana opinions naming this issue, 1982–2019 2 sentences 1989What forms any part of the res gestae is always admissible in evidence." LSA-R.S. 15:448 provides: "To constitute res gestae the circumstances and declarations must be necessary incidents of the criminal act, or immediate concomitants of it, or form in conjunction with it one continuous transaction." The Supreme Court discussed the res gestae exception in State v. Kimble, 407 So.2d 693, 698 (La.1981), stating: "In Louisiana, the res gestae doctrine is broad and includes not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witn 1989What forms any part of the res gestae is always admissible in evidence." LSA-R.S. 15:448 provides: "To constitute res gestae the circumstances and declarations must be necessary incidents of the criminal act, or immediate concomitants of it, or form in conjunction with it one continuous transaction." The Supreme Court discussed the res gestae exception in State v. Kimble, 407 So.2d 693, 698 (La.1981), stating: "In Louisiana, the res gestae doctrine is broad and includes not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witn	23	42
State v. Huizargreen la · 1982 · cited in 24 Louisiana opinions naming this issue, 1985–2025 2 sentences 2025State v. Odenbaugh, supra; State v. Huizar, 414 So. 2d 741 (La. 1982). 2019State v. Huizar , 414 So.2d 741 , 748 (La.1982) ; State v. Kimble , 407 So.2d 693 , 698 (La.1981).	19	24
State v. Schwartzgreen la · 1978 · cited in 9 Louisiana opinions naming this issue, 1981–2015 2 sentences 2015State v. Schwartz, 354 So.2d 1332, 1334 (La.1978) (collecting cases). 1990See State v. Schwartz, 354 So.2d 1332, 1334 (La.1978) and cases cited therein.	9	9
State v. Pacegreen la · 1974 · cited in 7 Louisiana opinions naming this issue, 1975–1990 2 sentences 1990See State v. Pace, 301 So.2d 323, 326 (La.1974); State v. Anderson, 526 So.2d 499, 502 (La.App. 1st Cir.1988), writ denied, 537 So.2d 1160 (1989). 1976ASSIGNMENTS OF ERROR NOS. 3 AND 4 In these two assignments of error, defendant contends that the trial court committed reversible error in allowing the victim's mother to testify that on the day of the offense, her daughter called her from her grandmother's house and said that she wanted to come home because she had something to tell her mother, and that when she came home she immediately started crying and screaming, dropped her clothes and game to the floor, and told her mother, "Derwin got me, mama." In State v. Pace, La., 301 So.2d 323 (1974), we held similar evidence admissible under the	4	7
State v. Boydgreen la · 1978 · cited in 4 Louisiana opinions naming this issue, 2000–2016 2 sentences 2016State v. Boyd, 359 So.2d 931, 942 (La. 1978); State v. Clift, 339 So.2d 755, 760 (La.1976). 2000State v. Boyd, 359 So.2d 931, 942 (La.1978); State v. Clift, 339 So.2d 755, 760 (La. 1976).	4	4
State v. Graniergreen lactapp · 1991 · cited in 4 Louisiana opinions naming this issue, 2002–2016 2 sentences 2016As noted by this Court in State v. Richardson, 13-886 (La.App. 5th Cir. 05/28/14), 142 So.3d 314, 325 , citing State v. Taylor, 01-1638 (La. 1/14/03), 838 So.2d 729 , cert. denied, 540 U.S. 1103 , 124 S.Ct. 1036 , 157 L.Ed.2d 886 (2004), "The res gestae doctrine is designed to allow the story of the crime to be told in its entirety, by proving its immediate context of happenings in time and place.” Furthermore, as explained by the Louisiana Fourth Circuit Court of Appeal in State v. Granier, 592 So.2d 883, 888 (La.App. 4th Cir.1991), "In order to constitute res gestae, the circumstances and de 2016As noted by this Court in State v. Richardson, 13-886 (La.App. 5th Cir. 05/28/14), 142 So.3d 314, 325 , citing State v. Taylor, 01-1638 (La. 1/14/03), 838 So.2d 729 , cert. denied, 540 U.S. 1103 , 124 S.Ct. 1036 , 157 L.Ed.2d 886 (2004), "The res gestae doctrine is designed to allow the story of the crime to be told in its entirety, by proving its immediate context of happenings in time and place.” Furthermore, as explained by the Louisiana Fourth Circuit Court of Appeal in State v. Granier, 592 So.2d 883, 888 (La.App. 4th Cir.1991), "In order to constitute res gestae, the circumstances and de	4	4
State v. Cliftgreen la · 1976 · cited in 4 Louisiana opinions naming this issue, 2000–2016 2 sentences 2016State v. Boyd, 359 So.2d 931, 942 (La. 1978); State v. Clift, 339 So.2d 755, 760 (La.1976). 2000State v. Boyd, 359 So.2d 931, 942 (La.1978); State v. Clift, 339 So.2d 755, 760 (La. 1976).	4	4
State v. Taylorgreen la · 2003 · cited in 22 Louisiana opinions naming this issue, 2003–2024 2 sentences 2018The Louisiana Supreme Court discussed at length the admissibility of a seven-day crime spree, which involved dozens of crimes through several states, including the defendant's kidnapping and murder of a victim in Louisiana, stating that "under the rule of narrative completeness incorporated in the res gestae doctrine 'the prosecution may fairly seek to place its evidence before the jurors, as much to tell a story of guiltiness as to support an inference of guilt, to convince the jurors a guilty verdict would be morally reasonable as much as to point to the discrete elements of a defendant's le 2016As noted by this Court in State v. Richardson, 13-886 (La.App. 5th Cir. 05/28/14), 142 So.3d 314, 325 , citing State v. Taylor, 01-1638 (La. 1/14/03), 838 So.2d 729 , cert. denied, 540 U.S. 1103 , 124 S.Ct. 1036 , 157 L.Ed.2d 886 (2004), "The res gestae doctrine is designed to allow the story of the crime to be told in its entirety, by proving its immediate context of happenings in time and place.” Furthermore, as explained by the Louisiana Fourth Circuit Court of Appeal in State v. Granier, 592 So.2d 883, 888 (La.App. 4th Cir.1991), "In order to constitute res gestae, the circumstances and de	3	22
State v. Colombgreen la · 1999 · cited in 12 Louisiana opinions naming this issue, 2000–2018 2 sentences 2018The Louisiana Supreme Court has interpreted the res gestae exception broadly, concluding that the exception includes "not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witnesses and police officers pertaining to what they heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances." State v. Colomb, 98-2813, pp. 3-4 (La. 10/1/99), 747 So.2d 1074 , 1075-1076 (quoting State v. Molinario, 383 So.2d 345 , 350 (La.1980) ). 2016As we previously noted, the Supreme Court: “... has interpreted the res gestae exception broadly, concluding that the exception includes ‘not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witnesses and police officers pertaining to what they 113heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances.’ ” State v. Falkins, 12-1654, p. 20 (La.App. 4 Cir. 7/23/14), 146 So.3d 838, 851 , quoting State v. Colomb, 98-2813, pp. 3-4 (La.10/1/99), 747	3	12
State v. Williamsgreen la · 1976 · cited in 5 Louisiana opinions naming this issue, 1985–1998 2 sentences 1985As stated by the Louisiana Supreme Court in State v. Williams, 331 So.2d 467 (La.1976), "res gestae includes spontaneous words or acts of the participants at the time of the occurrence, but `not the words of the participants when narrating the events.' As early recognized, the res gestae exception permits admission of events speaking thru participants, but not the testimony of participants speaking about events." Id. at 470 (citation omitted). 1985As stated by the Louisiana Supreme Court in State v. Williams, 331 So.2d 467 (La.1976), "res gestae includes spontaneous words or acts of the participants at the time of the occurrence, but `not the words of the participants when narrating the events.' As early recognized, the res gestae exception permits admission of events speaking thru participants, but not the testimony of participants speaking about events." Id. at 470 (citation omitted).	3	5
State v. Reesegreen la · 1967 · cited in 4 Louisiana opinions naming this issue, 1971–2013 2 sentences 2013“The res gestae doctrine includes the testimony of witnesses and police officers pertaining to what they heard or observed before, during or after the commission of the crime, provided there is a continuous chain of events under the circumstances.” State v. Brown, 03-1616, p. 14 (La.App. 4 Cir. 3/31/04), 871 So.2d 1240, 1250 ; see also State v. Reese, 250 La. 151 , 194 So.2d 729, 733-34 (1967); State v. Colomb, 98-2813, p. 3 (La.10/1/99), 747 So.2d 1074, 1076 . 2013“The res gestae doctrine includes the testimony of witnesses and police officers pertaining to what they heard or observed before, during or after the commission of the crime, provided there is a continuous chain of events under the circumstances.” State v. Brown, 03-1616, p. 14 (La.App. 4 Cir. 3/31/04), 871 So.2d 1240, 1250 ; see also State v. Reese, 250 La. 151 , 194 So.2d 729, 733-34 (1967); State v. Colomb, 98-2813, p. 3 (La.10/1/99), 747 So.2d 1074, 1076 .	3	4
State v. Belgardgreen la · 1982 · cited in 8 Louisiana opinions naming this issue, 1983–1988 2 sentences 1988Prieur recognized the res gestae exception to the inadmissibility of evidence of other crimes, and Prieur "does not require the state to provide notice to the defendant of crimes that fall within the res gestae exception." State v. Belgard, 410 So.2d 720, 723 (La.1982). 1988La.C.Cr.P. art. 720; State v. Belgard, 410 So.2d 720, 723 (La.1982).	2	8
State v. Currygreen la · 1976 · cited in 5 Louisiana opinions naming this issue, 1978–2018 2 sentences 2018In State v. Edwards , 406 So.2d 1331 , 1350-1351 (La. 1981), cert. denied , 456 U.S. 945 , 102 S.Ct. 2011 , 72 L.Ed.2d 467 (1982), the Louisiana Supreme Court held that other crimes evidence was properly admitted during the defendant's murder trial pursuant to the res gestae exception, noting that the evening's sequence of events formed "one continuous transaction," during which the murder with which the defendant was charged took place, and "without such evidence, the complete story of the crime could not be told." Id. at 1351, citing State v. Curry , 325 So.2d 598 , 602 (La. 1976). 2004As this court remarked in State v. Curry, 325 So.2d 598, 602 (La., 1976), "(w)ithout (such) evidence, the complete story of the crime (could) not be told." State v. Edwards, 406 So.2d at 1351 .	2	5
State v. Callowaygreen la · 1976 · cited in 3 Louisiana opinions naming this issue, 1990–2000 2 sentences 2000State v. Calloway, 324 So.2d 801, 809 (La.1975). 1991State v. Wille, supra, 559 So.2d at 1330 ; State v. Calloway, 324 So.2d 801 (La.1975); State v. Lard, 459 So.2d 1189 (La.App. 4th Cir. 1984), writ denied 464 So.2d 1376 (La.1985).	2	3
Manuel v. American Employers Insurance Companygreen lactapp · 1968 · cited in 3 Louisiana opinions naming this issue, 1972–1985	2	3
State v. Williamsgreen lactapp · 1993 · cited in 2 Louisiana opinions naming this issue, 2010–2016	2	2
State v. Velezgreen lactapp · 1991 · cited in 2 Louisiana opinions naming this issue, 1998–2016	2	2
State v. Parkergreen lactapp · 1988 · cited in 2 Louisiana opinions naming this issue, 2000–2000	2	2
State v. Washingtongreen lactapp · 1983 · cited in 2 Louisiana opinions naming this issue, 1989–1989	2	2
State v. Prieurred la · 1973 · cited in 7 Louisiana opinions naming this issue, 1982–2025 2 sentences 2025State v. Prieur, supra. The res gestae doctrine in Louisiana is broad and includes not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witnesses and police officers pertaining to what they heard or observed during or after the commission of the crime if a continuous chain of events is evident under the circumstances. 2016App. 3 Cir. 2/4/98), 709 So.2d 810, 818 , writ denied, 98-2461 (La. 1/29/99), 736 So.2d 827 , the court explained: “‘Evidence admissible under the res gestae exception to the general inadmissibility of other crimes evidence is not subject to any notice requirements.’ State v. Velez, 588 So.2d 116, 128 (La.App. 3 Cir.1991), writ denied, 592 So.2d 408 (La.1992), certiorari denied, 505 U.S. 1220 , 112 S.Ct. 3031 , 120 L.Ed.2d 901 (1992) citing State v. Prieur, 277 So.2d 126 (La.1973).” In this case, the trial court found the evidence constituted res gestae; thus, according to Arvie , the Defendan	1	7
State v. Molinariogreen la · 1980 · cited in 7 Louisiana opinions naming this issue, 1982–2018 2 sentences 2018The Louisiana Supreme Court has interpreted the res gestae exception broadly, concluding that the exception includes "not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witnesses and police officers pertaining to what they heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances." State v. Colomb, 98-2813, pp. 3-4 (La. 10/1/99), 747 So.2d 1074 , 1075-1076 (quoting State v. Molinario, 383 So.2d 345 , 350 (La.1980) ). 2014The Louisiana Supreme Court has interpreted the res gestae exception broadly, concluding that the exception includes “not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witnesses and police officers pertaining to what they heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances.” State v. Colomb, 98-2813, pp. 3-4 (La.10/1/99), 747 So.2d 1074, 1075-1076 (quoting State v. Molinario, 383 So.2d 345, 350 (La.1980)).	1	7
State v. Haaralagreen la · 1981 · cited in 6 Louisiana opinions naming this issue, 1984–2004 2 sentences 2004State v. Walker , XXXX-XXXX (La.10/12/01), 799 So.2d 461 . [4] In State v. Taylor , 838 So.2d at 758, fn. 8 , in a footnote the Court noted a number of cases in addition to State v. Haarala, 398 So.2d at 1093 , involving the res gestae exception: See also State v. Bilbo, 97-2189, pp. 9-10 (La.App. 1 Cir. 9/25/98), 719 So.2d 1134, 1139 (evidence defendant, charged with kidnapping, had stolen car from car dealership in Florida six days earlier by threatening car salesman while on test drive, had driven stolen car to California, and was involved in accident in Louisiana just before kidnapping vic 1989In State v. Haarala, 398 So.2d 1093 (La.1981) the Court defined and explained the “close connexity” requirement of the res gestae rule as follows: “The general prohibition against the use of other crimes evidence does not bar admission of criminal acts which are an inseparable part of the whole deed, (citation omitted) In Louisiana, such acts are denominated as part of the res ges-tae and admitted under the authority of La.R.S. 15:447-48.	1	6
State v. Prestridgegreen la · 1981 · cited in 6 Louisiana opinions naming this issue, 1984–1989 2 sentences 1989LSA-R.S. 15:447, 15:448; State v. Elzie, 351 So.2d 1174 (La.1977) State v. Prestridge, 399 So. 2d 564 (La.1981). 1988What forms any part of the res gestae is always admissible in evidence.” Our Supreme Court has expanded the res gestae exception to include the original complaint of a young child “... when the particular facts and circumstances of the case indicate that it was a product of a shocking episode and not a fabrication.” State v. Prestridge, 399 So.2d 564 (La.1981) at 572.	1	6
State v. Falkinsgreen lactapp · 2014 · cited in 4 Louisiana opinions naming this issue, 2015–2023 2 sentences 2016As we previously noted, the Supreme Court: “... has interpreted the res gestae exception broadly, concluding that the exception includes ‘not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witnesses and police officers pertaining to what they 113heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances.’ ” State v. Falkins, 12-1654, p. 20 (La.App. 4 Cir. 7/23/14), 146 So.3d 838, 851 , quoting State v. Colomb, 98-2813, pp. 3-4 (La.10/1/99), 747 2015As this Court noted, the Supreme Court: ... has interpreted the res gestae exception broadly, concluding that the exception includes ‘not only spontaneous utterances and declarations made before or after the commission of the crime, but also testimony of witnesses and police officers pertaining to what they heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances.’ ” State v. Falkins, 12-1654, p. 20 (La.App. 4 Cir. 7/23/14), 146 So.3d 838, 851 , quoting State v. Colomb, 98-2813, pp. 3-4 (La.10/1/99), 747 So.2d 1	1	4
State v. Feebackgreen la · 1982 · cited in 3 Louisiana opinions naming this issue, 1983–1993	1	3
State v. Clarkgreen lactapp · 1988 · cited in 2 Louisiana opinions naming this issue, 1992–1996	1	2
State v. Lardgreen lactapp · 1984 · cited in 2 Louisiana opinions naming this issue, 1990–1991	1	2
State v. Sharpgreen la · 1982 · cited in 2 Louisiana opinions naming this issue, 1983–1984	1	2
State v. Beangreen la · 1976 · cited in 2 Louisiana opinions naming this issue, 1978–1978	1	2
State v. Leonardgreen lactapp · 1989 · cited in 1 Louisiana opinions naming this issue, 2013–2013	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Louisiana. Read the followed side critically anyway.

Also cited on this issue (50)

Case	Cited	Years
Old Chief v. United States green scotus · 1997 2 sentences 2020Further, the res gestae doctrine incorporates a rule of narrative completeness by which, " the prosecution may fairly seek to place its evidence before the jurors, as much to tell a story of guiltiness as to support an inference of guilt, to convince the jurors a guilty verdict would be morally reasonable as much as to point to the discrete elements of a defendant' s legal fault." Id. ( quoting Old Chief, 519 U.S. at 188 , 117 S. Ct. at 654 .). 2020Further, the res gestae doctrine incorporates a rule of narrative completeness by which, " the prosecution may fairly seek to place its evidence before the jurors, as much to tell a story of guiltiness as to support an inference of guilt, to convince the jurors a guilty verdict would be morally reasonable as much as to point to the discrete elements of a defendant' s legal fault." Id. ( quoting Old Chief, 519 U.S. at 188 , 117 S. Ct. at 654 .).	9	2000–2020
Roadway Express, Inc. v. Fiske green scotus · 2004 2 sentences 2018The Louisiana Supreme Court discussed at length the admissibility of a seven-day crime spree, which involved dozens of crimes through several states, including the defendant's kidnapping and murder of a victim in Louisiana, stating that "under the rule of narrative completeness incorporated in the res gestae doctrine 'the prosecution may fairly seek to place its evidence before the jurors, as much to tell a story of guiltiness as to support an inference of guilt, to convince the jurors a guilty verdict would be morally reasonable as much as to point to the discrete elements of a defendant's le 2016As noted by this Court in State v. Richardson, 13-886 (La.App. 5th Cir. 05/28/14), 142 So.3d 314, 325 , citing State v. Taylor, 01-1638 (La. 1/14/03), 838 So.2d 729 , cert. denied, 540 U.S. 1103 , 124 S.Ct. 1036 , 157 L.Ed.2d 886 (2004), "The res gestae doctrine is designed to allow the story of the crime to be told in its entirety, by proving its immediate context of happenings in time and place.” Furthermore, as explained by the Louisiana Fourth Circuit Court of Appeal in State v. Granier, 592 So.2d 883, 888 (La.App. 4th Cir.1991), "In order to constitute res gestae, the circumstances and de	8	2006–2023
State v. Drew green la · 1978 2 sentences 1987The Louisiana Supreme Court, in State v. Drew, 360 So.2d 500 (La.1978), established the scope of the res gestae doctrine and stated: “... [R]es gestae doctrine in Louisiana is broad and includes not only spontaneous utterances and declarations made before and after commission of a crime but also includes testimony of witnesses and police officers pertaining to what they heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances.” Although the res gestae doctrine is broad, we find that the res gestae doctrine is no 1983The scope of the res gestae doctrine was established in State v. Drew, 360 So.2d 500 (La.1978) where the court reasoned: “... [R]es gestae doctrine in Louisiana is broad and includes not only spontaneous utterances and delcarations made before and after commission of crime but also includes testimony of witnesses and police officers pertaining to what they heard or observed before, during, or after the commission of the crime if the continuous chain of events is evident under the circumstances.” (Emphasis added) In the instant case, Clifford Alexander testified that, in the conversation which	7	1981–1994
In re Von Flowers green scotus · 2004 2 sentences 2016As noted by this Court in State v. Richardson, 13-886 (La.App. 5th Cir. 05/28/14), 142 So.3d 314, 325 , citing State v. Taylor, 01-1638 (La. 1/14/03), 838 So.2d 729 , cert. denied, 540 U.S. 1103 , 124 S.Ct. 1036 , 157 L.Ed.2d 886 (2004), "The res gestae doctrine is designed to allow the story of the crime to be told in its entirety, by proving its immediate context of happenings in time and place.” Furthermore, as explained by the Louisiana Fourth Circuit Court of Appeal in State v. Granier, 592 So.2d 883, 888 (La.App. 4th Cir.1991), "In order to constitute res gestae, the circumstances and de 2006State v. Brown, 03-1616 (La.App. 4 Cir. 3/31/04) , 871 So.2d 1240 ; writ denied, 04-1285 (La.10/15/04), 883 So.2d 1044 ; State v. Williams, 03-0987 (La.App. 4 Cir. 12/10/03) , 863 So.2d 652 ; writ denied, 04-0261 (La.6/04/04), 876 So.2d 75 (noting that if the evidence of other crimes is introduced because it was an integral part of the act that is the subject of the case, no advance notice is required). \|7The Louisiana Supreme Court discussed the res gestae principle in State v. Taylor, 01-1638, pp. 10-11 (La.1/14/03), 838 So.2d 729, 741-42 , cert. denied, Taylor v. Louisiana, 540 U.S. 1103 ,	5	2006–2023
Maryland v. Wallace green scotus · 2004 2 sentences 2016As noted by this Court in State v. Richardson, 13-886 (La.App. 5th Cir. 05/28/14), 142 So.3d 314, 325 , citing State v. Taylor, 01-1638 (La. 1/14/03), 838 So.2d 729 , cert. denied, 540 U.S. 1103 , 124 S.Ct. 1036 , 157 L.Ed.2d 886 (2004), "The res gestae doctrine is designed to allow the story of the crime to be told in its entirety, by proving its immediate context of happenings in time and place.” Furthermore, as explained by the Louisiana Fourth Circuit Court of Appeal in State v. Granier, 592 So.2d 883, 888 (La.App. 4th Cir.1991), "In order to constitute res gestae, the circumstances and de 2006State v. Brown, 03-1616 (La.App. 4 Cir. 3/31/04) , 871 So.2d 1240 ; writ denied, 04-1285 (La.10/15/04), 883 So.2d 1044 ; State v. Williams, 03-0987 (La.App. 4 Cir. 12/10/03) , 863 So.2d 652 ; writ denied, 04-0261 (La.6/04/04), 876 So.2d 75 (noting that if the evidence of other crimes is introduced because it was an integral part of the act that is the subject of the case, no advance notice is required). \|7The Louisiana Supreme Court discussed the res gestae principle in State v. Taylor, 01-1638, pp. 10-11 (La.1/14/03), 838 So.2d 729, 741-42 , cert. denied, Taylor v. Louisiana, 540 U.S. 1103 ,	5	2006–2023
State v. Walker green lactapp · 2000 2 sentences 2007In considering the assignment of error, this Court noted that counsel may have believed that any objection to the evidence would have been overruled by the trial court on the grounds that the evidence was admissible under the res gestae exception because the evidence "was so closely related to the State's case as to the charge of felon in possession of a firearm." Walker, p. 8, 775 So.2d at 489 . 2007Prior to discussing whether the defendant's counsel may have not objected as a matter of trial strategy, the Court discussed the res gestae exception and indicated that the evidence was admissible under it, noting that the police officers' "narrative testimony established that all of the events leading up to the defendant's arrest . . . occurred within a short period of time." Walker, p. 7, 775 So.2d at 489 .	5	2004–2012
State v. Adams green la · 1981 2 sentences 1989See State v. Prestridge, 399 So.2d 564 (La. 1981); State v. Adams, 394 So.2d 1204 (La.1981); State v. Hatcher, 372 So.2d 1024 (La.1979). 1987The original complaint of the young child is the statement made at the first reasonable opportunity under the particular facts and circumstances of the case." State v. Prestridge, 399 So.2d 564 (La.1981); State v. Adams, 394 So.2d 1204 (La.1981); State v. Hatcher, 372 So.2d 1024 (La.1979); State v. Noble, 342 So.2d 170 (La.1977); State v. Pace, 301 So.2d 323 (La.1974); State v. Garay, 453 So.2d 1003 (La.App. 4th Cir.1984).	5	1984–1989
State v. Batiste green la · 1975 2 sentences 1985LSA-R.S. 15:447, 448; State v. Drew, 360 So.2d 500 (La.1978); State v. Batiste, 318 So.2d 27 (La.1975). 1985LSA-R.S. 15:447, 448; State v. Drew, 360 So.2d 500 (La.1978); State v. Batiste, 318 So.2d 27 (La.1975).” State v. Kimble, 407 So.2d 693 (La.1981). “ ‘Res gestae’ declarations are admitted as an exception to the hearsay rule on the theory that spontaneous and impulsive statements, made at substantially the same time as the occurrence, without time for deliberation and fabrication, are truthful.	5	1977–1985
State v. Brewington green la · 1992 2 sentences 2000The Louisiana Supreme Court commented on the res gestae exception in State v. Brewington, 601 So.2d 656 (La.1992), stating: This court has approved the admission of other crimes evidence when it is related and intertwined with the charged offense to such an extent that the state could not have accurately presented its case without reference to it. 2000Explaining the res gestae exception, the Louisiana Supreme Court, in State v. Brewington, 601 So.2d 656 (La.1992) stated: This court has approved the admission of other crimes evidence when it is related and intertwined with the charged offense to such an extent that the state could not have accurately presented its case without reference to it.	4	2000–2004
State v. Edwards green la · 1981 2 sentences 2018In State v. Edwards , 406 So.2d 1331 , 1350-1351 (La. 1981), cert. denied , 456 U.S. 945 , 102 S.Ct. 2011 , 72 L.Ed.2d 467 (1982), the Louisiana Supreme Court held that other crimes evidence was properly admitted during the defendant's murder trial pursuant to the res gestae exception, noting that the evening's sequence of events formed "one continuous transaction," during which the murder with which the defendant was charged took place, and "without such evidence, the complete story of the crime could not be told." Id. at 1351, citing State v. Curry , 325 So.2d 598 , 602 (La. 1976). 2004As this court remarked in State v. Curry, 325 So.2d 598, 602 (La., 1976), "(w)ithout (such) evidence, the complete story of the crime (could) not be told." State v. Edwards, 406 So.2d at 1351 .	3	1984–2018
State v. Brown green lactapp · 2004 2 sentences 2013“The res gestae doctrine includes the testimony of witnesses and police officers pertaining to what they heard or observed before, during or after the commission of the crime, provided there is a continuous chain of events under the circumstances.” State v. Brown, 03-1616, p. 14 (La.App. 4 Cir. 3/31/04), 871 So.2d 1240, 1250 ; see also State v. Reese, 250 La. 151 , 194 So.2d 729, 733-34 (1967); State v. Colomb, 98-2813, p. 3 (La.10/1/99), 747 So.2d 1074, 1076 . 2006State v. Brown, 03-1616 (La.App. 4 Cir. 3/31/04) , 871 So.2d 1240 ; writ denied, 04-1285 (La.10/15/04), 883 So.2d 1044 ; State v. Williams, 03-0987 (La.App. 4 Cir. 12/10/03) , 863 So.2d 652 ; writ denied, 04-0261 (La.6/04/04), 876 So.2d 75 (noting that if the evidence of other crimes is introduced because it was an integral part of the act that is the subject of the case, no advance notice is required). \|7The Louisiana Supreme Court discussed the res gestae principle in State v. Taylor, 01-1638, pp. 10-11 (La.1/14/03), 838 So.2d 729, 741-42 , cert. denied, Taylor v. Louisiana, 540 U.S. 1103 ,	3	2006–2014
Watson v. Watson green la · 1984	3	1985–1989
State v. Noble green la · 1977	3	1984–1987
State v. Brown green la · 1981	3	1982–1987
Downing v. Easton Hospital green scotus · 1980	3	1982–1984
Baker v. Indiana green scotus · 1980	3	1982–1984
Molinario v. Louisiana green scotus · 1980	3	1982–1984
Chia v. Westinghouse Electric Corp. green scotus · 1982	2	1984–2018
St. Louis Southwestern Railway Co. v. Brotherhood of Railroad Signalmen green scotus · 1982	2	1984–2018
Incorporated Trustees of the Gospel Worker Society v. United States green scotus · 1982	2	1984–2018
State v. Odenbaugh green la · 2011	2	2013–2017
State v. Cooley neutral lactapp · 2012	2	2017–2017
State v. Cooley neutral la · 2013	2	2017–2017
State v. Velez green la · 1992	2	1998–2016
Lucas v. Schneider National Carriers, Inc. green scotus · 1992	2	1998–2016
Ellis v. United States green scotus · 1992	2	1998–2016
Atchison, Topeka & Santa Fe Railway Co. v. Southern California Rapid Transit District green scotus · 1992	2	1998–2016
State v. FLOT green la · 2010	2	2011–2013
State v. Williams green lactapp · 2003	2	2004–2006
STATE EX REL. PARKER v. State neutral la · 1991	2	2000–2000
State v. Reaux green lactapp · 1989	2	1990–1991
State v. Craddock green lactapp · 1983	2	1990–1991
State v. Gibson neutral la · 1985	2	1990–1991
State v. Hatcher green la · 1979	2	1987–1989
State v. Brown green la · 1974	2	1984–1989
State v. Elzie green la · 1977	2	1989–1989
State v. Mitchell green la · 1983	2	1984–1987
State v. Millet green la · 1978	2	1982–1983
State v. Mays green la · 1975	2	1978–1978
State v. Morgan green la · 1974	2	1975–1977

Statutes the citing opinions construe

LA § La. Rev. Stat. § 15:447 (73) LA § La. Rev. Stat. § 40:967 (31) LA § La. Rev. Stat. § 14:30.1 (28) LA § La. Rev. Stat. § 14:27 (24) LA § La. Rev. Stat. § 14:64 (23) LA § La. Rev. Stat. § 15:529.1 (21) LA § La. Rev. Stat. § 15:434 (17) LA § La. Rev. Stat. § 15:438 (17) LA § La. Rev. Stat. § 14:10 (16) LA § La. Rev. Stat. § 14:30 (15) LA § La. Rev. Stat. § 40:966 (15) LA § La. Rev. Stat. § 15:441 (13)

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 231 (1925–2026) LA 177 (1956–2025) GA 107 (1957–2017) TX 78 (1923–2020) WA 68 (1926–2026) MI 51 (1948–2020) IN 49 (1958–2023) MO 47 (1930–2025) CO 40 (1954–2026) AL 34 (1916–2026) OK 28 (1967–2022) SC 25 (1930–2021) IA 24 (1911–1995) VA 23 (1922–2025) IL 21 (1926–2014) AR 20 (1976–2026) FL 14 (1966–2008) MN 13 (1922–2015) NC 12 (1962–2007) CA 12 (1937–1986) KY 12 (1909–1985) OH 12 (1944–2006) MD 11 (1969–2011) WV 11 (1878–2020) MT 11 (1938–2001) NJ 11 (1952–2021) KS 10 (1979–2017) NY 10 (1893–2003) UT 10 (1903–2025) ID 10 (1894–2024) AZ 9 (1923–1975) SD 9 (1968–2017) NM 9 (1939–2010) WI 7 (1968–1989) TN 7 (1939–2014) NV 6 (1980–2026) VT 5 (1935–1987) MS 4 (1934–2005) HI 4 (1982–2008) OR 4 (1957–2024) ME 3 (1923–1972) DC 2 (1945–2004) MA 2 (1955–1983) NH 2 (1977–1981) WY 2 (1941–1992)

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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