identity exception (Missouri) · Go Syfert
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identity exception in Missouri

18 Missouri opinions name it 2 courts 1976–2019 0 in the last five years

The cases below were cited by Missouri 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 (13)

CaseFollowedCited
State v. Bernardgreen
mo · 1993 · cited in 5 Missouri opinions naming this issue, 1993–2016
2 sentences

2016See Bernard, 849 S.W.2d at 17 (“[f]or the prior conduct to fall within the identity exception, there must be more than mere similarity between the crime charged and the uncharged crime”); see also Davis, 211 S.W.3d at 87-89 (holding uncharged robbery was not sufficiently similar to be admissible under the identity exception in case involving charged robbery because although the two crimes had multiple similarities, they were different in several respects).

2016See Bernard, 849 S.W.2d at 17 (“[f]or the prior conduct to fall within the identity exception, there must be more than mere similarity between the crime charged and the uncharged crime”); see also Davis, 211 S.W.3d at 87-89 (holding uncharged robbery was not sufficiently similar to be admissible under the identity exception in case involving charged robbery because although the two crimes had multiple similarities, they were different in several respects).

35
State v. Austingreen
moctapp · 2013 · cited in 2 Missouri opinions naming this issue, 2016–2016
2 sentences

2016See Austin, 411 S.W.3d at 294 .

2016See Austin, 411 S.W.3d at 294 . g.

22
State v. Davisgreen
mo · 2006 · cited in 2 Missouri opinions naming this issue, 2016–2016
2 sentences

2016See Bernard, 849 S.W.2d at 17 (“[f]or the prior conduct to fall within the identity exception, there must be more than mere similarity between the crime charged and the uncharged crime”); see also Davis, 211 S.W.3d at 87-89 (holding uncharged robbery was not sufficiently similar to be admissible under the identity exception in case involving charged robbery because although the two crimes had multiple similarities, they were different in several respects).

2016See Bernard, 849 S.W.2d at 17 (“[f]or the prior conduct to fall within the identity exception, there must be more than mere similarity between the crime charged and the uncharged crime”); see also Davis, 211 S.W.3d at 87-89 (holding uncharged robbery was not sufficiently similar to be admissible under the identity exception in case involving charged robbery because although the two crimes had multiple similarities, they were different in several respects).

22
State v. McDanielsgreen
moctapp · 1984 · cited in 2 Missouri opinions naming this issue, 1993–1993
2 sentences

1993State v. McDaniels, 668 S.W.2d 230, 232-33 (Mo.App.1984); State v. Young, 661 S.W.2d 637, 639 (Mo.App.1983).

1993The court further stated that for prior misconduct to be classified within this established exception and admissible, “[t]he charged and uncharged crimes must be nearly ‘identical’ and their methodology ‘so unusual and distinctive’ that they resemble a ‘signature’ of the defendant’s involvement in both crimes.” Id. at 16-17 (quoting State v. McDaniels, 668 S.W.2d 230, 232-33 (Mo.App.1984); State v. Young, 661 S.W.2d 637, 639 (Mo.App.1983)).

22
State v. Younggreen
moctapp · 1983 · cited in 2 Missouri opinions naming this issue, 1993–1993
2 sentences

1993State v. McDaniels, 668 S.W.2d 230, 232-33 (Mo.App.1984); State v. Young, 661 S.W.2d 637, 639 (Mo.App.1983).

1993The court further stated that for prior misconduct to be classified within this established exception and admissible, “[t]he charged and uncharged crimes must be nearly ‘identical’ and their methodology ‘so unusual and distinctive’ that they resemble a ‘signature’ of the defendant’s involvement in both crimes.” Id. at 16-17 (quoting State v. McDaniels, 668 S.W.2d 230, 232-33 (Mo.App.1984); State v. Young, 661 S.W.2d 637, 639 (Mo.App.1983)).

22
Calmese v. Stategreen
moctapp · 1990 · cited in 1 Missouri opinions naming this issue, 2003–2003
1 sentence

2003See id.

11
State v. Vowellgreen
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 2003–2003
1 sentence

2003Anthony, 881 S.W.2d at 660; State v. Vowell, 863 S.W.2d 954, 957 (Mo.App.1993).

11
Maddox v. Truman Medical Center, Inc.green
moctapp · 1987 · cited in 1 Missouri opinions naming this issue, 2000–2000
1 sentence

2000Maddox v. Truman Medical Center, Inc., 727 S.W.2d 152, 155 (Mo.App.1987).

11
State v. Reesegreen
mo · 1954 · cited in 1 Missouri opinions naming this issue, 1995–1995
1 sentence

1995The court not only held the evidence admissible to prove consciousness of guilt but also said, “[A]l-though we need not discuss the point further ... such evidence could also fall within the identity exception to the rule against showing prior offenses.” Id. at 840 ; citing State v. Reese, 274 S.W.2d 304, 307 (Mo. banc 1954).

11
State v. McKinneygreen
moctapp · 1986 · cited in 1 Missouri opinions naming this issue, 1987–1987
1 sentence

1987“It has long been held in Missouri that identity of names is prima facie evidence of the identity of person.” State v. McKinney, 718 S.W.2d 583, 586 (Mo.App.1986).

11
State v. Thomasgreen
moctapp · 1976 · cited in 1 Missouri opinions naming this issue, 1981–1981
1 sentence

1981State v. Thomas, 541 S.W.2d 775, 777 (Mo.App.1976).

11
State v. Collorgreen
mo · 1973 · cited in 1 Missouri opinions naming this issue, 1976–1976
1 sentence

1976This argument has been advanced several times in Missouri cases, but the rule remains that the inclusion of a separate cautionary identity instruction is discretionary, State v. Collor, 502 S.W.2d 258, 259 (Mo.1973); State v. Taylor, 472 S.W.2d 395, 402 (Mo.1971) and State v. Letourneau, 515 S.W.2d 838 (Mo. App.1974).

11
State v. Taylorgreen
mo · 1971 · cited in 1 Missouri opinions naming this issue, 1976–1976
1 sentence

1976This argument has been advanced several times in Missouri cases, but the rule remains that the inclusion of a separate cautionary identity instruction is discretionary, State v. Collor, 502 S.W.2d 258, 259 (Mo.1973); State v. Taylor, 472 S.W.2d 395, 402 (Mo.1971) and State v. Letourneau, 515 S.W.2d 838 (Mo. App.1974).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (11)

CaseCitedYears
White v. Director of Revenue green
mo · 2010
1 sentence

2019Further, records properly deposited with DHSS are admissible in courts and in administrative proceedings if certified by a proper custodian 3 Mr. Carvalho suggests White, 321 S.W.3d at 307 , effectively overruled Turcotte and its progeny.

12019–2019
State v. Vorhees green
mo · 2008
1 sentence

2018State v. Vorhees , 248 S.W.3d 585 , 590 (Mo. banc 2008), abrogated in part by article I, section 18(c) of the Missouri Constitution, ("Signature evidence used for corroboration is, at base, propensity evidence masquerading under the well-recognized identity exception, a category of exception in which it does not belong.").

12018–2018
State v. Branam green
moctapp · 2016
1 sentence

2018As explained in State v. McBenge ,"[e]vidence is logically relevant under the identity exception if the identity of the wrongdoer is at issue, and the State demonstrates the defendant is the perpetrator who has committed the charged crime by showing defendant or his accomplice has committed other uncharged acts which are sufficiently similar to the crime charged with respect to time, place, and method." 507 S.W.3d 94 , 116 (Mo. App. E.D. 2016).

12018–2018
Cervantes v. Time, Inc. green
scotus · 1973
1 sentence

1997The point of principal importance is that there *655 must be a showing of cognizable prejudice before the failure to permit examination of anonymous news sources can rise to the level of error.” Id. at 994 .

11997–1997
State v. Corlew green
mo · 1971
1 sentence

1995The court not only held the evidence admissible to prove consciousness of guilt but also said, “[A]l-though we need not discuss the point further ... such evidence could also fall within the identity exception to the rule against showing prior offenses.” Id. at 840 ; citing State v. Reese, 274 S.W.2d 304, 307 (Mo. banc 1954).

11995–1995
State v. Conley green
mo · 1994
1 sentence

1994However, the Court in Bernard went on to recognize a related exception known as the ‘signature modus operandi /corroboration exception.’ That exception, similar to the identity exception, authorized evidence of an uncharged crime if the offenses are nearly identical and their methodology so unusual and distinctive that they amount to a signature of the defendant involved in both crimes.” Conley, 873 S.W.2d at 236 .

11994–1994
State v. Koster green
moctapp · 1984
2 sentences

1993Koster, 684 S.W.2d at 491 .

1993Koster, 684 S.W.2d at 491 .

11993–1993
State v. Brooks green
moctapp · 1991
2 sentences

1993As the court of appeals noted in State v. Brooks, 810 S.W.2d 627 (Mo.App.1991), the result has been that “the common scheme or plan exception [is] being conflated or mixed with the identity exception; the definitional lines separating these two exceptions [has] become blurred; and the trial court admits evidence of other crimes without a clear rationale for doing so.” Id. at 633 .

1993As the court of appeals noted in State v. Brooks, 810 S.W.2d 627 (Mo.App.1991), the result has been that “the common scheme or plan exception [is] being conflated or mixed with the identity exception; the definitional lines separating these two exceptions [has] become blurred; and the trial court admits evidence of other crimes without a clear rationale for doing so.” Id. at 633 .

11993–1993
Jones v. State green
alacrimapp · 1984
2 sentences

1992Jones, 460 So.2d at 1390 .

1992Jones, 460 So.2d at 1390 .

11992–1992
United States v. Melvin Telfaire green
cadc · 1972
2 sentences

1976On appeal, he suggests that the trial court should have given an identity instruction based on the model instruction discussed in United States v. Telfaire, 152 U.S.App.D.C. 146 , 469 F.2d 552 (1972).

1976On appeal, he suggests that the trial court should have given an identity instruction based on the model instruction discussed in United States v. Telfaire, 152 U.S.App.D.C. 146 , 469 F.2d 552 (1972).

11976–1976
State v. Letourneau green
moctapp · 1974
1 sentence

1976This argument has been advanced several times in Missouri cases, but the rule remains that the inclusion of a separate cautionary identity instruction is discretionary, State v. Collor, 502 S.W.2d 258, 259 (Mo.1973); State v. Taylor, 472 S.W.2d 395, 402 (Mo.1971) and State v. Letourneau, 515 S.W.2d 838 (Mo. App.1974).

11976–1976

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 566.100 (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

AL 66 (1906–2015) CT 65 (1982–2026) NY 42 (1852–2026) TX 38 (1932–2025) IL 25 (1976–2022) PA 25 (1979–2026) IN 25 (1972–2025) CA 20 (1887–2025) MO 18 (1976–2019) MD 17 (1941–2025) AZ 15 (1967–2020) IA 12 (1914–2017) NM 12 (1977–2024) GA 11 (1980–2025) FL 11 (1980–2021) DC 10 (1976–2020) NC 9 (1982–2014) OH 8 (1933–2022) TN 8 (1997–2015) WA 7 (1976–2024) OR 6 (1976–2006) NV 6 (1978–2020) MN 6 (1972–2016) OK 5 (1980–2020) VA 4 (1969–2000) KS 4 (1991–2026) MT 3 (2010–2020) CO 3 (1988–2021) MA 3 (1990–2015) SD 2 (1979–1992) ID 2 (1977–2013) WI 2 (1999–2005) SC 2 (2020–2025) WV 2 (1983–2013) MS 2 (2005–2007) HI 2 (1978–2013)

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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