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24 Minnesota opinions name it 2 courts 1984–2016 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.
| Case | Followed | Cited |
|---|---|---|
Ohio v. Robertsred2 sentences2012Prior to Crawford, the admissibility of an out-of-court statement under the Confrontation Clause turned primarily on evidentiary rules and “indicia of reliability.” Ohio v. Roberts, 448 U.S. 56, 66 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980) (concluding that no independent Confrontation Clause analysis is necessary if a statement “falls within a firmly rooted hearsay exception” or bears “particularized guarantees of trustworthiness”). 2012Prior to Crawford, the admissibility of an out-of-court statement under the Confrontation Clause turned primarily on evidentiary rules and “indicia of reliability.” Ohio v. Roberts, 448 U.S. 56, 66 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980) (concluding that no independent Confrontation Clause analysis is necessary if a statement “falls within a firmly rooted hearsay exception” or bears “particularized guarantees of trustworthiness”). | 2 | 18 |
Idaho v. Wrightgreen2 sentences1995See Wright, 497 U.S. at 811-12, 815 , 110 S.Ct. at 3144, 3146 (holding that Idaho Rule of Evidence 803(24) is not a firmly rooted hearsay exception for Confrontation Clause purposes); State v. Larson, 472 N.W.2d 120, 125 (Minn.1991) (noting that residual hearsay exceptions are not firmly rooted for Confrontation Clause purposes). 8 . 1995See Wright, 497 U.S. at 811-12, 815 , 110 S.Ct. at 3144, 3146 (holding that Idaho Rule of Evidence 803(24) is not a firmly rooted hearsay exception for Confrontation Clause purposes); State v. Larson, 472 N.W.2d 120, 125 (Minn.1991) (noting that residual hearsay exceptions are not firmly rooted for Confrontation Clause purposes). 8 . | 2 | 4 |
Lilly v. Virginiagreen2 sentences2001Lilly, 527 U.S. at 134 , 119 S.Ct. 1887 . 2001Lilly, 527 U.S. at 134 , 119 S.Ct. 1887 . | 1 | 2 |
State v. Bristgreen1 sentence2016The Minnesota Supreme Court recognized in State v. Brist that courts are required “to conduct a separate Confrontation Clause analysis for out-of-court ‘testimonial’ statements, even when the statements at issue otherwise satisfy a firmly- rooted hearsay exception.” 812 N.W.2d 51, 56 (Minn. 2012).4 Applying the Davis factors to this case, J.C.-L.’s statements to Detective Parranto in the ambulance were nontestimonial, and therefore admissible at trial. | 1 | 1 |
Melendez-Diaz v. Massachusettsgreen2 sentences2012See, e.g., Melendez-Diaz v. Massachusetts, 557 U.S. 305 , —, 129 S.Ct. 2527, 2540 , 174 L.Ed.2d 314 (2009) (holding that certificates of analysis produced by forensic scientists who conducted a chemical analysis of drugs seized from the defendant are subject to Confrontation Clause challenge “[wjhether or not they qualify as business or official records”); Davis v. Washington, 547 U.S. 813, 821 , 126 S.Ct. 2266 , 165 L.Ed.2d 224 (2006) (subjecting “excited utterances” to Confrontation Clause analysis). 2012See, e.g., Melendez-Diaz v. Massachusetts, 557 U.S. 305 , —, 129 S.Ct. 2527, 2540 , 174 L.Ed.2d 314 (2009) (holding that certificates of analysis produced by forensic scientists who conducted a chemical analysis of drugs seized from the defendant are subject to Confrontation Clause challenge “[wjhether or not they qualify as business or official records”); Davis v. Washington, 547 U.S. 813, 821 , 126 S.Ct. 2266 , 165 L.Ed.2d 224 (2006) (subjecting “excited utterances” to Confrontation Clause analysis). | 1 | 1 |
State v. Martingreen2 sentences2008In State v. Martin, decided before Davis , we indicated that nontestimonial statements had to meet the Roberts test to be admitted consistent with the Confrontation Clause. 695 N.W.2d 578, 584 (Minn.2005). 2008In State v. Martin, decided before Davis , we indicated that nontestimonial statements had to meet the Roberts test to be admitted consistent with the Confrontation Clause. 695 N.W.2d 578, 584 (Minn.2005). | 1 | 1 |
White v. Illinoisgreen2 sentences2004See White v. Illinois, 502 U.S. 346, 358 , 112 S.Ct. 736, 744 , 116 L.Ed.2d 848 (1992) (holding that Confrontation Clause is not violated when testimonial statements of child/victim of a sexual assault to an investigation police officer were properly admitted as spontaneous declarations). 2004See White v. Illinois, 502 U.S. 346, 358 , 112 S.Ct. 736, 744 , 116 L.Ed.2d 848 (1992) (holding that Confrontation Clause is not violated when testimonial statements of child/victim of a sexual assault to an investigation police officer were properly admitted as spontaneous declarations). | 1 | 1 |
State v. Larsongreen1 sentence1995See Wright, 497 U.S. at 811-12, 815 , 110 S.Ct. at 3144, 3146 (holding that Idaho Rule of Evidence 803(24) is not a firmly rooted hearsay exception for Confrontation Clause purposes); State v. Larson, 472 N.W.2d 120, 125 (Minn.1991) (noting that residual hearsay exceptions are not firmly rooted for Confrontation Clause purposes). 8 . | 1 | 1 |
State v. Danielsgreen2 sentences1991State v. Daniels, 380 N.W.2d 777, 785-86 (Minn.1986). 1991State v. Daniels, 380 N.W.2d 777, 785-86 (Minn.1986). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Crawford v. Washington
green
2 sentences2008Prior to the Supreme Court's decision in Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 , the admissibility of a statement by an unavailable hearsay declarant satisfied the Confrontation Clause if the statement bore "adequate `indicia of reliability,'" and an out-of-court statement was deemed sufficiently reliable if it fell "within a firmly rooted hearsay exception" or bore "particularized guarantees of trustworthiness." Ohio v. Roberts, 448 U.S. 56, 66 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980). 2008Prior to the Supreme Court's decision in Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 , the admissibility of a statement by an unavailable hearsay declarant satisfied the Confrontation Clause if the statement bore "adequate `indicia of reliability,'" and an out-of-court statement was deemed sufficiently reliable if it fell "within a firmly rooted hearsay exception" or bore "particularized guarantees of trustworthiness." Ohio v. Roberts, 448 U.S. 56, 66 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980). | 7 | 2005–2016 |
Michigan v. Bryant
green
1 sentence2016This is no longer the case after Crawford. 541 U.S. at 53-54 , 124 S. Ct. at 1365-66 . 11 Michigan v. Bryant, 562 U.S. 344, 349 , 131 S. Ct. 1142 , 1050 (2011) (holding that statements made by a gunshot victim in response to informal police questioning about a shooting event when the victim appeared to be in great pain and spoke with difficulty were not testimonial). | 1 | 2016–2016 |
Giles v. California
green
2 sentences2012In fact it did not violate the Confrontation Clause for the quite different reason that it was not (as an incriminating statement in further-anee of the conspiracy would probably never be) testimonial. 554 U.S. 353 , 374 n. 6, 128 S.Ct. 2678 , 171 L.Ed.2d 488 (2008) (plurality opinion). 3 Because the Court has never overruled Bourjaily , and has actually endorsed Bourjaily in three of its recent decisions, we conclude that Bourjaily remains good law. 2012In fact it did not violate the Confrontation Clause for the quite different reason that it was not (as an incriminating statement in further-anee of the conspiracy would probably never be) testimonial. 554 U.S. 353 , 374 n. 6, 128 S.Ct. 2678 , 171 L.Ed.2d 488 (2008) (plurality opinion). 3 Because the Court has never overruled Bourjaily , and has actually endorsed Bourjaily in three of its recent decisions, we conclude that Bourjaily remains good law. | 1 | 2012–2012 |
Davis v. Washington
green
2 sentences2012See, e.g., Melendez-Diaz v. Massachusetts, 557 U.S. 305 , —, 129 S.Ct. 2527, 2540 , 174 L.Ed.2d 314 (2009) (holding that certificates of analysis produced by forensic scientists who conducted a chemical analysis of drugs seized from the defendant are subject to Confrontation Clause challenge “[wjhether or not they qualify as business or official records”); Davis v. Washington, 547 U.S. 813, 821 , 126 S.Ct. 2266 , 165 L.Ed.2d 224 (2006) (subjecting “excited utterances” to Confrontation Clause analysis). 2012See, e.g., Melendez-Diaz v. Massachusetts, 557 U.S. 305 , —, 129 S.Ct. 2527, 2540 , 174 L.Ed.2d 314 (2009) (holding that certificates of analysis produced by forensic scientists who conducted a chemical analysis of drugs seized from the defendant are subject to Confrontation Clause challenge “[wjhether or not they qualify as business or official records”); Davis v. Washington, 547 U.S. 813, 821 , 126 S.Ct. 2266 , 165 L.Ed.2d 224 (2006) (subjecting “excited utterances” to Confrontation Clause analysis). | 1 | 2012–2012 |
Bourjaily v. United States
green
2 sentences2012Finally, in Giles v. California, a plurality of the Court unambiguously endorsed the continuing vitality of Bourjaily: Bourjaily v. United States, 483 U.S. 171 [ 107 S.Ct. 2775 , 97 L.Ed.2d 144 ] (1987), held that admission of the evidence did not violate the Confrontation Clause because it falls within a firmly rooted hearsay exception — the test under Ohio v. Roberts, 448 U.S. 56, 66 [ 100 S.Ct. 2531 , 65 L.Ed.2d 597 ] (1980), the case that Crawford overruled. 2012Finally, in Giles v. California, a plurality of the Court unambiguously endorsed the continuing vitality of Bourjaily: Bourjaily v. United States, 483 U.S. 171 [ 107 S.Ct. 2775 , 97 L.Ed.2d 144 ] (1987), held that admission of the evidence did not violate the Confrontation Clause because it falls within a firmly rooted hearsay exception — the test under Ohio v. Roberts, 448 U.S. 56, 66 [ 100 S.Ct. 2531 , 65 L.Ed.2d 597 ] (1980), the case that Crawford overruled. | 1 | 2012–2012 |
Mancusi v. Stubbs
green
2 sentences2008Ohio v. Roberts, the precursor to Crawford and Davis , required nontestimonial statements to bear "adequate ‘indicia of reliability’ ” — either falling within “a firmly rooted hearsay exception" or bearing "particularized guarantees of trustworthiness.” 448 U.S. 56, 66 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980) (quoting Mancusi v. Stubbs, 408 U.S. 204, 213 , 92 S.Ct. 2308 , 33 L.Ed.2d 293 (1972)). 2008Ohio v. Roberts, the precursor to Crawford and Davis , required nontestimonial statements to bear "adequate ‘indicia of reliability’ ” — either falling within “a firmly rooted hearsay exception" or bearing "particularized guarantees of trustworthiness.” 448 U.S. 56, 66 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980) (quoting Mancusi v. Stubbs, 408 U.S. 204, 213 , 92 S.Ct. 2308 , 33 L.Ed.2d 293 (1972)). | 1 | 2008–2008 |
Lee v. Illinois
green
2 sentences1993The Confrontation Clause of the Sixth Amendment provides: “In all criminal prosecutions, the accused shall enjoy the right * * * to be confronted with the witnesses against him.” Statements that do not fall within a firmly rooted hearsay exception are “presumptively unreliable and inadmissible for Confrontation Clause purposes.” Idaho v. Wright, 497 U.S. 805, 817 , 110 S.Ct. 3139, 3148 , 111 L.Ed.2d 638 (1990) (citing Lee v. U.S., 476 U.S. 530 at 543 , 106 S.Ct. 2056, 2063 , 90 L.Ed.2d 514 ). 1993The Confrontation Clause of the Sixth Amendment provides: “In all criminal prosecutions, the accused shall enjoy the right * * * to be confronted with the witnesses against him.” Statements that do not fall within a firmly rooted hearsay exception are “presumptively unreliable and inadmissible for Confrontation Clause purposes.” Idaho v. Wright, 497 U.S. 805, 817 , 110 S.Ct. 3139, 3148 , 111 L.Ed.2d 638 (1990) (citing Lee v. U.S., 476 U.S. 530 at 543 , 106 S.Ct. 2056, 2063 , 90 L.Ed.2d 514 ). | 1 | 1993–1993 |
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.
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.