Turner test (Michigan) · Go Syfert
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Turner test in Michigan

18 Michigan opinions name it 2 courts 1976–2024 7 in the last five years

The cases below were cited by Michigan 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 (3)

CaseFollowedCited
People v. Wilkigreen
michctapp · 1984 · cited in 2 Michigan opinions naming this issue, 1995–1998
2 sentences

1998In People v Wilki, supra at 144, yet another panel of this Court, concerned that “the Turner standard will not always be an easy one to apply,” interpreted “very strong evidence” to mean “evidence such that the police, acting in good faith, have no reasonable necessity for confirming that the suspect they have apprehended is in fact the perpetrator.” Id. at 144 . 6 We believe that Dixon and Turner fail to provide a simple, practical standard consistent with Anderson for use by police officers in the field.

1998In People v Wilki, supra at 144, yet another panel of this Court, concerned that “the Turner standard will not always be an easy one to apply,” interpreted “very strong evidence” to mean “evidence such that the police, acting in good faith, have no reasonable necessity for confirming that the suspect they have apprehended is in fact the perpetrator.” Id. at 144 . 6 We believe that Dixon and Turner fail to provide a simple, practical standard consistent with Anderson for use by police officers in the field.

12
Foster v. Cone-Blanchard MacHine Co.green
mich · 1999 · cited in 1 Michigan opinions naming this issue, 2015–2015
2 sentences

2015See Foster, 460 Mich at 703 (describing the Turner doctrine).

2015See Foster, 460 Mich at 703 (describing the Turner doctrine).

11
Stovall v. Dennogreen
scotus · 1967 · cited in 1 Michigan opinions naming this issue, 1998–1998
2 sentences

1998Moore, supra at 227 ; see also Stovall, supra; Marks, supra at 217 .

1998Moore, supra at 227 ; see also Stovall, supra; Marks, supra at 217 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
Turner v. United States green
scotus · 2017
2 sentences

2022Turner, ___ US at ___; 137 S Ct at 1889 .

2022Turner, ___ US at ___; 137 S Ct at 1889 .

62022–2022
People v. Turner green
mich · 1973
2 sentences

1991People v Turner, 390 Mich 7 ; 210 NW2d 336 (1973).

1991People v Turner, 390 Mich 7 ; 210 NW2d 336 (1973).

31976–1991
Turner v. Auto Club Ins. Ass'n green
mich · 1995
2 sentences

2024Turner, 448 Mich at 39 .

2024Turner, 448 Mich at 39 .

22014–2024
Moore v. Illinois green
scotus · 1977
2 sentences

1998Moore, supra at 227 ; see also Stovall, supra; Marks, supra at 217 .

1998Moore, supra at 227 ; see also Stovall, supra; Marks, supra at 217 .

11998–1998
People v. Marks green
michctapp · 1986
2 sentences

1998Moore, supra at 227 ; see also Stovall, supra; Marks, supra at 217 .

1998Moore, supra at 227 ; see also Stovall, supra; Marks, supra at 217 .

11998–1998
People v. Turner green
michctapp · 1982
2 sentences

1998Turner, supra at 37 . 6 The Wilki Court’s concern about the Turner rule is, to say the least, an understatement. 7 Again, we believe that due process provides sufficient protection against unreliable pretrial identifications obtained through unnecessarily suggestive procedures.

1998Turner, supra at 37 . 6 The Wilki Court’s concern about the Turner rule is, to say the least, an understatement. 7 Again, we believe that due process provides sufficient protection against unreliable pretrial identifications obtained through unnecessarily suggestive procedures.

11998–1998
People v. Patskan green
mich · 1972
2 sentences

1986Much of the motivation behind the Turner rule seems to be the Court’s effort to reconcile People v Patskan, 387 Mich 701 ; 199 NW2d 458 (1972), with the Supreme Court’s later recognition of the on-the-scene identification exception in Anderson .

1986Much of the motivation behind the Turner rule seems to be the Court’s effort to reconcile People v Patskan, 387 Mich 701 ; 199 NW2d 458 (1972), with the Supreme Court’s later recognition of the on-the-scene identification exception in Anderson .

11986–1986
People v. Missouri green
michctapp · 1980
1 sentence

1982Missouri supra, Tenerowicz, supra. VII Defendants Bivins, Iaconnelli, Harold Davis, and Turner claim that their convictions must be reversed because, although they were charged with involvement in a single mass conspiracy, the proofs presented during trial demonstrated, at best, the existence of multiple, separate conspiracies.

11982–1982
Trimper v. Bruno-Sherman Corp. green
mied · 1977
2 sentences

1981In Trimper v Bruno-Sherman Corp, 436 F Supp 349 (ED Mich, 1977) the court found both continuity of the enterprise between the predecessor and successor corporation and that the successor held itself out as the predecessor corporation as the bases for estopping the successor corporation from denying liability to innocent third parties.

1981In Trimper v Bruno-Sherman Corp, 436 F Supp 349 (ED Mich, 1977) the court found both continuity of the enterprise between the predecessor and successor corporation and that the successor held itself out as the predecessor corporation as the bases for estopping the successor corporation from denying liability to innocent third parties.

11981–1981
Tuttle v. Department of State Highways green
mich · 1976
2 sentences

1979Tuttle v Dep’t of State Highways, 397 Mich 44, 46 ; 243 NW2d 244 (1976).

1979Tuttle v Dep’t of State Highways, 397 Mich 44, 46 ; 243 NW2d 244 (1976).

11979–1979
United States v. Russell green
scotus · 1973
2 sentences

1978In People v Turner, 390 Mich 7 ; 210 NW2d 336 (1973), the Michigan Supreme Court adopted an objective test of entrapment, relying on the dissenting opinion of Justice Stewart in United States v Russell, 411 US 423 ; 93 S Ct 1637 ; 36 L Ed 2d 366 (1973), which states: "But when the agents’ involvement in criminal activities goes beyond the mere offering of such an opportunity, and when their conduct is of a kind that could induce or instigate the commission of a crime by one not ready and willing to commit it, then — regardless of the character or propensities of the particular person induced —

1978In People v Turner, 390 Mich 7 ; 210 NW2d 336 (1973), the Michigan Supreme Court adopted an objective test of entrapment, relying on the dissenting opinion of Justice Stewart in United States v Russell, 411 US 423 ; 93 S Ct 1637 ; 36 L Ed 2d 366 (1973), which states: "But when the agents’ involvement in criminal activities goes beyond the mere offering of such an opportunity, and when their conduct is of a kind that could induce or instigate the commission of a crime by one not ready and willing to commit it, then — regardless of the character or propensities of the particular person induced —

11978–1978
People v. Zeegers green
michctapp · 1975
2 sentences

1976The Michigan Court of Appeals has followed that interpretation of Turner, supra. People v Zeegers, 61 Mich App 546 ; 233 NW2d 76 (1975).

1976The Michigan Court of Appeals has followed that interpretation of Turner, supra. People v Zeegers, 61 Mich App 546 ; 233 NW2d 76 (1975).

11976–1976

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 15.231 (6)

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

CA 27 (1948–2025) TX 26 (1923–2026) PA 23 (1966–2024) MI 18 (1976–2024) MS 18 (1991–2025) FL 15 (1982–2012) NY 14 (1994–2025) IN 14 (1980–2019) OH 13 (2000–2025) WA 13 (1999–2025) GA 12 (1998–2026) IL 12 (1977–2023) KS 10 (1986–2024) AK 8 (1998–2024) VA 8 (1977–2022) MA 8 (1988–2023) AL 8 (1985–2011) LA 6 (1969–2019) OR 6 (1987–2019) WI 6 (1996–2026) NV 5 (1982–2020) DC 5 (1982–2022) NJ 4 (1981–2007) KY 4 (1998–2026) ID 4 (1982–2020) NM 4 (2003–2026) MD 3 (1973–2012) MO 3 (2001–2016) NC 3 (1994–2013) AZ 3 (1993–2015) UT 3 (2004–2021) SC 3 (2012–2025) IA 3 (2014–2026) NE 2 (2016–2016)

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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