trustworthiness standard (Texas) · Go Syfert
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trustworthiness standard in Texas

19 Texas opinions name it 2 courts 1986–2018 0 in the last five years

The cases below were cited by Texas 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 (12)

CaseFollowedCited
People v. LaRosagreen
colo · 2013 · cited in 4 Texas opinions naming this issue, 2013–2015
2 sentences

2013See People v. LaRosa, 293 P.3d 567, 573-74 (Colo.2013) (abandoning the corpus delicti rule in favor of the trustworthiness standard).

2013See People v. LaRosa , 293 P.3d 567, 573-74 (Colo. 2013) (abandoning the corpus delicti rule in favor of the trustworthiness standard).

44
Muttoni v. Stategreen
texapp · 2000 · cited in 4 Texas opinions naming this issue, 2002–2003
2 sentences

2003The trustworthiness requirement is satisfied if cross-examination would be of only "marginal utility." Muttoni v. State , 25 S.W.3d 300, 307 (Tex. App.-Austin 2000, no pet.) (citing Lilly , 527 U.S. at 134 ).

2003The trustworthiness requirement is satisfied if cross-examination would be of only “marginal utility.” Muttoni v. State, 25 S.W.3d 300, 307 (Tex.App.-Austin 2000, no pet.) (citing Lilly, 527 U.S. at 134 , 119 S.Ct. 1887 ).

44
Commonwealth v. Fordegreen
mass · 1984 · cited in 2 Texas opinions naming this issue, 2015–2015
2 sentences

2015See, e.g., Massachusetts v. Forde, 392 Mass. 453 , 466 N.E.2d 510, 513 (1984) (adopting the corpus delicti rule after the United States Supreme Court adopted a trustworthiness standard and stating that, although the “rule has been criticized, and diluted ... [,] it precludes the possibility of conviction of [a] crime based solely on statements made by a person suffering a mental or emotional disturbance or some other aberration”).

2015See, e.g., Massachusetts v. Forde, 392 Mass. 453 , 466 N.E.2d 510, 513 (1984) (adopting the corpus delicti rule after the United States Supreme Court adopted a trustworthiness standard and stating that, although the “rule has been criticized, and diluted ... [,] it precludes the possibility of conviction of [a] crime based solely on statements made by a person suffering a mental or emotional disturbance or some other aberration”).

22
Jackson v. Virginiared
scotus · 1979 · cited in 2 Texas opinions naming this issue, 2015–2015
2 sentences

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

22
United States v. Calderongreen
scotus · 1954 · cited in 2 Texas opinions naming this issue, 2015–2015
2 sentences

2015However, the rule has also been criticized because it does not protect mentally infirm individuals who confess to a real crime when there is other corroborating evidence, it can result in the exclusion of reliable confessions, the perpetrator of a crime against a non-verbal person that suffers an intangible injury could not be convicted unless there is other corroborating evidence, and the rule is obsolete because of other developments in the law. 9 When the United States Supreme Court addressed this issue, it adopted a trustworthiness standard in lieu of the corpus de-licti rule, and that sta

2015However, the rule has also been criticized because it does not protect mentally infirm individuals who confess to a real crime when there is other corroborating evidence, it can result in the exclusion of reliable confessions, the perpetrator of a crime against a non-verbal person that suffers an intangible injury could not be convicted unless there is other corroborating evidence, and the rule is obsolete because of other developments in the law. 9 When the United States Supreme Court addressed this issue, it adopted a trustworthiness standard in lieu of the corpus de-licti rule, and that sta

22
Smith v. United Statesgreen
scotus · 1954 · cited in 2 Texas opinions naming this issue, 2015–2015
2 sentences

2015However, the rule has also been criticized because it does not protect mentally infirm individuals who confess to a real crime when there is other corroborating evidence, it can result in the exclusion of reliable confessions, the perpetrator of a crime against a non-verbal person that suffers an intangible injury could not be convicted unless there is other corroborating evidence, and the rule is obsolete because of other developments in the law. 9 When the United States Supreme Court addressed this issue, it adopted a trustworthiness standard in lieu of the corpus de-licti rule, and that sta

2015However, the rule has also been criticized because it does not protect mentally infirm individuals who confess to a real crime when there is other corroborating evidence, it can result in the exclusion of reliable confessions, the perpetrator of a crime against a non-verbal person that suffers an intangible injury could not be convicted unless there is other corroborating evidence, and the rule is obsolete because of other developments in the law. 9 When the United States Supreme Court addressed this issue, it adopted a trustworthiness standard in lieu of the corpus de-licti rule, and that sta

22
Opper v. United Statesgreen
scotus · 1954 · cited in 2 Texas opinions naming this issue, 2015–2015
2 sentences

2015However, the rule has also been criticized because it does not protect mentally infirm individuals who confess to a real crime when there is other corroborating evidence, it can result in the exclusion of reliable confessions, the perpetrator of a crime against a non-verbal person that suffers an intangible injury could not be convicted unless there is other corroborating evidence, and the rule is obsolete because of other developments in the law. 9 When the United States Supreme Court addressed this issue, it adopted a trustworthiness standard in lieu of the corpus de-licti rule, and that sta

2015However, the rule has also been criticized because it does not protect mentally infirm individuals who confess to a real crime when there is other corroborating evidence, it can result in the exclusion of reliable confessions, the perpetrator of a crime against a non-verbal person that suffers an intangible injury could not be convicted unless there is other corroborating evidence, and the rule is obsolete because of other developments in the law. 9 When the United States Supreme Court addressed this issue, it adopted a trustworthiness standard in lieu of the corpus de-licti rule, and that sta

22
Gribble v. Stategreen
texcrimapp · 1991 · cited in 2 Texas opinions naming this issue, 2015–2015
2 sentences

2015See, e.g., Colorado v. LaRosa, 293 P.3d 9 Cf. Colorado v. LaRosa, 293 P.3d 567, 574 (Colo. 2013) (listing criticisms leveled against the corpus delicti rule, including that the court was “troubled that the rule works to bar convictions in cases involving the most vulnerable victims, such as infants, young children, and the mentally infirm” and that “the rule operates disproportionately in cases where no tangible injury results, such as in cases involving inappropriate sexual contact, or where criminal agency is difficult or impossible to prove, such as in cases involving infanticide or child a

2015See, e.g., Colorado v. LaRosa, 293 P.3d 9 Cf. Colorado v. LaRosa, 293 P.3d 567, 574 (Colo. 2013) (listing criticisms leveled against the corpus delicti rule, including that the court was “troubled that the rule works to bar convictions in cases involving the most vulnerable victims, such as infants, young children, and the mentally infirm” and that “the rule operates disproportionately in cases where no tangible injury results, such as in cases involving inappropriate sexual contact, or where criminal agency is difficult or impossible to prove, such as in cases involving infanticide or child a

22
Phea v. Stategreen
texapp · 1989 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018Phea v. State, 767 S.W.2d 263, 267 (Tex. App.—Amarillo 1989, pet. ref’d).

11
Gohring v. Stategreen
texapp · 1998 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Gohring v. State, 967 S.W.2d 459, 452 (Tex.App.—Beaumont 1998, no pet.).

11
Fontenot v. Stategreen
oklacrimapp · 1994 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015See, e.g., Colorado v. LaRosa, 293 P.3d 567, 575 (Colo.2013); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.Crim.App.1994); State v. Osborne, 335 S.C. 172 , 516 S.E.2d 201, 204-05 (1999).

11
State v. Osbornegreen
sc · 1999 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015See, e.g., Colorado v. LaRosa, 293 P.3d 567, 575 (Colo.2013); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.Crim.App.1994); State v. Osborne, 335 S.C. 172 , 516 S.E.2d 201, 204-05 (1999).

2015See, e.g., Colorado v. LaRosa, 293 P.3d 567, 575 (Colo.2013); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.Crim.App.1994); State v. Osborne, 335 S.C. 172 , 516 S.E.2d 201, 204-05 (1999).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
Beech Aircraft Corp. v. Rainey green
scotus · 1988
2 sentences

2007As long as the conclusion is based on a factual investigation and satisfies the Rule’s trustworthiness requirement, it should be admissible along with other portions of the report.” Id. at 170 , 109 S.Ct. at 450 .

2007As long as the conclusion is based on a factual investigation and satisfies the Rule’s trustworthiness requirement, it should be admissible along with other portions of the report.” Id. at 170 , 109 S.Ct. at 450 .

41992–2007
Lilly v. Virginia green
scotus · 1999
2 sentences

2003The trustworthiness requirement is satisfied if cross-examination would be of only “marginal utility.” Muttoni v. State, 25 S.W.3d 300, 307 (Tex.App.-Austin 2000, no pet.) (citing Lilly, 527 U.S. at 134 , 119 S.Ct. 1887 ).

2003The trustworthiness requirement is satisfied if cross-examination would be of only “marginal utility.” Muttoni v. State, 25 S.W.3d 300, 307 (Tex.App.-Austin 2000, no pet.) (citing Lilly, 527 U.S. at 134 , 119 S.Ct. 1887 ).

42002–2003
Blackburn v. Alabama green
scotus · 1960
2 sentences

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

22015–2015
Watts v. Indiana green
scotus · 1949
2 sentences

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

22015–2015
Rogers v. Tennessee green
scotus · 2001
2 sentences

2015In Rogers v. Tennessee, 532 U.S. 451 (2001), the United States Supreme Court reviewed a decision from the Tennessee Supreme Court in which it abolished the common law “year and a day rule.” That rule states that a person who injures another cannot be prosecuted for homicide if the injured person does not die within a year and a day of the person’s act.

2015In Rogers v. Tennessee, 532 U.S. 451 (2001), the United States Supreme Court reviewed a decision from the Tennessee Supreme Court in which it abolished the common law “year and a day rule.” That rule states that a person who injures another cannot be prosecuted for homicide if the injured person does not die within a year and a day of the person’s act.

22015–2015
Escobedo v. Illinois green
scotus · 1964
2 sentences

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

22015–2015
Miranda v. Arizona green
scotus · 1966
2 sentences

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

2015The State fails to expound on its broad argument for 6 See, e.g., Jackson, 443 U.S. at 319 (holding that the conviction of an accused is not constitutionally sound unless “the record evidence could reasonably support a finding of guilt beyond a reasonable doubt” by any rational trier of fact); Miranda v. Arizona, 384 U.S. 436 , 471–72 (1966) (holding that, before the prosecution can argue that an accused waived any of his rights, he must be apprised of his rights and knowingly, intelligently, voluntarily waive those rights or the confession is involuntary); Escobedo v. Illinois, 378 U.S. 478 ,

22015–2015
Idaho v. Wright green
scotus · 1990
2 sentences

1999The trustworthiness requirement is satisfied if it can be concluded that cross-examination would be of only "marginal utility." Id. at 819 , 110 S.Ct. 3139 .

1999The trustworthiness requirement is satisfied if it can be concluded that cross-examination would be of only "marginal utility." Id. at 819 , 110 S.Ct. 3139 .

21999–2000
Miller, Christopher Adrian green
texcrimapp · 2015
2 sentences

2015Id.

2015Id. at 927 .

12015–2015
Cofield v. State green
texcrimapp · 1994
1 sentence

2005Therefore, we sustain appellant's complaint that the statements did not meet the trustworthiness requirement under the declaration-against-interest exception to the hearsay rule. (6) See id . ; Cofield , 891 S.W.2d at 956 ; Tex. R.

12005–2005
Guidry v. State green
texcrimapp · 1999
1 sentence

2000Guidry , 9 S.W.3d at 150 (citing Wright , 497 U.S. at 819 ).

12000–2000
United States v. Luis Esteban Veytia-Bravo green
ca5 · 1979
1 sentence

1986Veytia-Bravo, 603 F.2d at 1191 .

11986–1986

Statutes the citing opinions construe

TX § Tex. Penal Code § 22.011 (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

IN 31 (2007–2020) CA 28 (1976–2026) TX 19 (1986–2018) NJ 18 (1983–2026) FL 11 (2002–2025) MN 10 (1984–2025) NM 10 (1994–2021) MS 10 (2001–2022) UT 9 (1987–2025) MI 9 (1990–2023) NC 7 (1987–2021) OK 6 (1994–2024) CO 5 (2000–2023) IL 5 (2007–2013) NV 5 (1991–2015) HI 5 (1989–2019) SD 4 (2003–2015) GA 4 (1998–2026) NY 4 (1980–1995) WA 4 (1993–2017) KS 4 (2014–2024) CT 3 (2006–2019) PA 3 (1973–2003) ID 3 (2003–2011) WI 3 (2022–2024) TN 3 (2014–2015) IA 2 (2020–2021) ME 2 (2018–2019) VA 2 (2011–2012) MD 2 (1994–2004) VT 2 (2014–2015) OH 2 (1999–2009) AL 2 (2003–2011) AZ 2 (1990–2015) ND 2 (2014–2021)

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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