Crawford rule (Pennsylvania) · Go Syfert
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Crawford rule in Pennsylvania

18 Pennsylvania opinions name it 3 courts 1984–2026 4 in the last five years

The cases below were cited by Pennsylvania 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 (9)

CaseFollowedCited
Commonwealth v. Claygreen
pa · 2013 · cited in 2 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021In evaluating Crawford’s claim that all his convictions are against the weight of the evidence, our review concerns the trial court’s exercise of discretion in denying relief, “not of the underlying question of whether the verdict is against the weight of the evidence.” Commonwealth v. Clay, 64 A.3d 1049, 1054-55 (Pa. 2013). “[A]n appellate court will give the gravest consideration to the findings and reasons advanced by the trial judge when reviewing a trial court’s determination that the verdict is against the weight of the evidence.” Id.

2021In evaluating Crawford’s claim that all his convictions are against the weight of the evidence, our review concerns the trial court’s exercise of discretion in denying relief, “not of the underlying question of whether the verdict is against the weight of the evidence.” Commonwealth v. Clay, 64 A.3d 1049, 1054-55 (Pa. 2013). “[A]n appellate court will give the gravest consideration to the findings and reasons advanced by the trial judge when reviewing a trial court’s determination that the verdict is against the weight of the evidence.” Id.

22
United States v. Hendricksgreen
ca3 · 2005 · cited in 2 Pennsylvania opinions naming this issue, 2006–2018
2 sentences

2018Hendricks, 395 F.3d at 181-83.

2018Hendricks, 395 F.3d at 181-83.

12
Commonwealth v. Hardygreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Williams, supra; see also Commonwealth v. Hardy, 918 A.2d 766, 771 (Pa. Super. 2007) (“This Court will not act as counsel and will not develop arguments on behalf of an appellant.”).

11
Commonwealth v. Williamsgreen
pasuperct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
2 sentences

2026See Pa.R.A.P. ____________________________________________ 11 42 Pa.C.S.A. §§ 9799.10-9799.42. 12In light of our disposition, we make no determination as to whether the hearsay statements satisfied the excited utterance exception. -4- J-A08011-26 1925(b)(4)(vii); Pa.R.A.P. 302(a) (“[I]ssues not raised in the [trial] court are waived and cannot be raised for the first time on appeal.”); see also Commonwealth v. Williams, 900 A.2d 906, 909 (Pa. Super. 2006) (“including an issue in a [c]oncise [s]tatement does not revive issues that were waived in earlier proceedings”).

2026See Williams, supra; see also Commonwealth v. Hardy, 918 A.2d 766, 771 (Pa. Super. 2007) (“This Court will not act as counsel and will not develop arguments on behalf of an appellant.”).

11
Kh v. Jrgreen
pa · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
2 sentences

2023See K.H. v. J.R., 826 A.2d 863 , 870-71 (Pa. 2003). 3 At the time of the final order from which it appeals, Crawford’s was pursuing claims relating to sixteen of those insureds.

2023See K.H. v. J.R., 826 A.2d 863, 870-71 (Pa. 2003). 3 At the time of the final order from which it appeals, Crawford’s was pursuing claims relating to sixteen of those insureds.

11
Commonwealth v. Robinsongreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Com. v. Robinson, 817 A.2d 1153, 1161 (Pa. Super. 2003) (“There is no requirement that the items taken in a theft or robbery be recovered.”). - 17 - J-A17006-15 Once the jury determined that Kemp knew his assailant, and rejected Kemp’s recantation of his prior statement, Crawford’s challenge to the sufficiency of the evidence supporting his identification as the perpetrator of the crime failed.

11
Travelers Indemnity Co. v. Fantozzi Ex Rel. Fantozzigreen
paed · 1993 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
1 sentence

2006Appellants’ brief at 11, citing Travelers Indemnity Co. v. Fantozzi, 825 F.Supp. 80, 84 (E.D.Pa.1993), citing in turn Crawford v. Manhattan Life.

11
cluster 294528green
ca3 · 1971 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
2 sentences

2006The Third Circuit’s application of the Crawford rule began with its analysis in Boase v. Lee Rubber Co., 437 F.2d 527 (3d.Cir.1970), wherein the court of appeals noted our Supreme Court had not expressly applied the Griffith rule, Griffith v. United Air Lines, Inc., 416 Pa. 1 , 203 A.2d 796 (1964), to a contract dispute from the time the Griffith decision was handed down until 1970 and that, consequently, Crawford was controlling law in the Commonwealth.

2006The Third Circuit’s application of the Crawford rule began with its analysis in Boase v. Lee Rubber Co., 437 F.2d 527 (3d.Cir.1970), wherein the court of appeals noted our Supreme Court had not expressly applied the Griffith rule, Griffith v. United Air Lines, Inc., 416 Pa. 1 , 203 A.2d 796 (1964), to a contract dispute from the time the Griffith decision was handed down until 1970 and that, consequently, Crawford was controlling law in the Commonwealth.

11
United States v. James Saget, Also Known as Heshgreen
ca2 · 2004 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
2 sentences

2006Id., 395 F.3d at 183 ; see also United States v. Saget, 377 F.3d 223, 229 (2d Cir.2004) (holding that the defendant’s statements to a Cl were “non-testimonial” because he had no knowledge of the Cl’s connection to investigators and believed that he was having a casual conversation with a Mend and potential co-conspirator). ¶21 First, we note that the recorded conversations on the audio tape do not fall within any of the three specific examples of “testimonial” evidence given by the Crawford court.

2006Id., 395 F.3d at 183 ; see also United States v. Saget, 377 F.3d 223, 229 (2d Cir.2004) (holding that the defendant’s statements to a Cl were “non-testimonial” because he had no knowledge of the Cl’s connection to investigators and believed that he was having a casual conversation with a Mend and potential co-conspirator). ¶21 First, we note that the recorded conversations on the audio tape do not fall within any of the three specific examples of “testimonial” evidence given by the Crawford court.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Crawford v. Washington green
scotus · 2004
2 sentences

2018Although counsel lodged a hearsay objection at trial, we do not agree that objection encompassed his present claim that the admission of Santiago’s statement to DeJesus was violative of the Confrontation Clause, as interpreted by Crawford, supra. Nevertheless, we conclude that Colon’s present Crawford claim has no arguable merit, and accordingly, counsel was not ineffective for failing to raise the issue in the trial court.

2005De fense counsel cannot be deemed ineffective for failing to raise a Crawford challenge to the testimony of other witnesses, when the victim’s testimony was challenged by the “crucible of cross-examination.” Crawford, 541 U.S. at 61 , 124 S.Ct. at 1370 , 158 L.Ed.2d at 199 .

52005–2018
Commonwealth v. Farmer green
pasuperct · 2000
1 sentence

2019Id.

12019–2019
Commonwealth v. Dargan green
pasuperct · 2006
2 sentences

2016In Commonwealth v. Dargan, 897 A.2d 496 (Pa. Super. 2006), the Superior Court held that an informant's statements to police describing the defendant's drug activity was not subject to a Crawford challenge where the statements were offered to explain the officer's investigation.

2016In Commonwealth v. Dargan, 897 A.2d 496 (Pa. Super. 2006), the Superior Court held that an informant's statements to police describing the defendant's drug activity was not subject to a Crawford challenge where the statements were offered to explain the officer's investigation.

12016–2016
Whorton v. Bockting green
scotus · 2007
2 sentences

2007Notably, however, in Whorton v. Bockting, - U.S. -, 127 S.Ct. 1173 , 167 L.Ed.2d 1 , 75 USLW 4121 (2007), it was determined the Crawford rule does not apply retroactively in that it announced a new rule of criminal procedure.

2007Notably, however, in Whorton v. Bockting, - U.S. -, 127 S.Ct. 1173 , 167 L.Ed.2d 1 , 75 USLW 4121 (2007), it was determined the Crawford rule does not apply retroactively in that it announced a new rule of criminal procedure.

12007–2007
Griffith v. United Air Lines, Inc. green
pa · 1964
2 sentences

2006The Third Circuit’s application of the Crawford rule began with its analysis in Boase v. Lee Rubber Co., 437 F.2d 527 (3d.Cir.1970), wherein the court of appeals noted our Supreme Court had not expressly applied the Griffith rule, Griffith v. United Air Lines, Inc., 416 Pa. 1 , 203 A.2d 796 (1964), to a contract dispute from the time the Griffith decision was handed down until 1970 and that, consequently, Crawford was controlling law in the Commonwealth.

2006The Third Circuit’s application of the Crawford rule began with its analysis in Boase v. Lee Rubber Co., 437 F.2d 527 (3d.Cir.1970), wherein the court of appeals noted our Supreme Court had not expressly applied the Griffith rule, Griffith v. United Air Lines, Inc., 416 Pa. 1 , 203 A.2d 796 (1964), to a contract dispute from the time the Griffith decision was handed down until 1970 and that, consequently, Crawford was controlling law in the Commonwealth.

12006–2006
Wilson v. Transport Ins. Co. green
pasuperct · 2005
2 sentences

2006The Peele Opinion is an anomaly as multiple decisions by this Court apply the Griffith rule to choice of law questions centered on contract disputes and, further, Peele is in conflict with this Court’s most recent precedent, which applies the Griffith rule in the contract context. 6 See Wilson, supra at 570 .

2006The Peele Opinion is an anomaly as multiple decisions by this Court apply the Griffith rule to choice of law questions centered on contract disputes and, further, Peele is in conflict with this Court’s most recent precedent, which applies the Griffith rule in the contract context. 6 See Wilson, supra at 570 .

12006–2006
Commonwealth v. Weeks green
pasuperct · 2003
1 sentence

2005Appellant cannot use Section 9543.1 to raise extraneous issues not related to DNA testing in an effort to avoid the one-year time bar. 5 We have held that a PCRA petition cannot be used to make a motion for DNA analysis, Weeks, supra, and the reverse is surely true as well.

12005–2005
Fox v. State Automobile Mutual Insurance green
pasuperct · 1983
2 sentences

1984The plaintiff relies upon Fox v. State Automobile Mutual Insurance Co., 314 Pa. Super. 559 , 461 A.2d 299 (1983), for the proposition that there can be a claim for injuries under the No-fault Act even after the operation of the vehicle in question has ceased.

1984The plaintiff relies upon Fox v. State Automobile Mutual Insurance Co., 314 Pa. Super. 559 , 461 A.2d 299 (1983), for the proposition that there can be a claim for injuries under the No-fault Act even after the operation of the vehicle in question has ceased.

11984–1984

Where else courts name it

TX 141 (1996–2025) CA 128 (1982–2026) NY 61 (1988–2026) IL 49 (1999–2021) FL 33 (2002–2019) OH 27 (2002–2025) GA 27 (1993–2025) WA 22 (1999–2012) CT 21 (1995–2025) TN 20 (1982–2025) PA 18 (1984–2026) MI 17 (1980–2020) OR 17 (2004–2015) LA 16 (1992–2014) VA 15 (2004–2023) MN 14 (2005–2018) KY 14 (2006–2025) MS 14 (1994–2016) NM 12 (2004–2022) WI 11 (2005–2022) KS 11 (1994–2014) MD 11 (2006–2021) MA 10 (2005–2018) CO 9 (2004–2025) IN 9 (2004–2017) NC 9 (2005–2023) NJ 9 (2007–2021) MO 8 (1997–2019) NH 7 (2007–2019) MT 6 (2002–2021) NV 5 (2009–2026) AZ 5 (2005–2019) IA 4 (2009–2022) DC 4 (2007–2012) WV 4 (2009–2021) SC 4 (2005–2014) ID 4 (2006–2015) AL 4 (2005–2014) AK 3 (2006–2021) AR 3 (2005–2015) OK 2 (2009–2012) HI 2 (2005–2007) UT 2 (1997–2005) SD 2 (2007–2018) DE 2 (2006–2017)

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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