firmly rooted exception (Pennsylvania) · Go Syfert
← Pennsylvania issues

firmly rooted exception in Pennsylvania

15 Pennsylvania opinions name it 2 courts 1990–2026 3 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 (11)

CaseFollowedCited
Ohio v. Robertsred
scotus · 1980 · cited in 7 Pennsylvania opinions naming this issue, 2006–2026
2 sentences

2026Prior to the decision in Crawford, supra, “the United States Supreme Court was of the view the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule or that bore a particularized guarantee of trustworthiness.” Brown, 185 A.3d at 324 , citing Crawford, 541 U.S. at 40 and Ohio v. Roberts, 448 U.S. 56, 66 (1980); see also Commonwealth v. Carter, 932 A.2d 1261 , 1265 n.3 (Pa. 2007).

2016Prior to the United States Supreme Court’s decision in Crawford v. Washington, 541 U.S. 36 (2004), it was generally the view that “the Confrontation Clause did not bar the admission of out-of–court statements that fell within a firmly rooted exception to the hearsay rule." Ohio v. Roberts, 448 U.S. 56 (1980) (abrogated by Crawford).

47
Commonwealth v. Younggreen
pa · 1999 · cited in 3 Pennsylvania opinions naming this issue, 2002–2024
2 sentences

2024Appellant further claims Officer Horton’s testimony does not fall within any exception to the hearsay rule: [T]he United States Supreme Court and the Pennsylvania Supreme Court have held that “[s]tatements made to the authorities by a non-testifying accomplice which inculpate the defendant more than the accomplice are not admissible pursuant -6- J-A11043-24 to a firmly rooted exception to the hearsay doctrine.” Commonwealth v. Robins, 812 A.2d [522, 524] (Pa. 2000)[,] quoting Commonwealth v. Young, 748 A.2d 166, 192 (Pa. 2000).

2002Concerning the question of firm rooting, on reargument in Commonwealth v. Young, 561 Pa. 34 , 748 A.2d 166 (2000), this Court acknowledged that the lead opinion in Lilly represented the view of a plurality of Justices but nonetheless was able to discern a majority holding on a point of law from among the various expressions. 12 This Court summarized that holding as follows: “[Statements made to the authorities by a non-testifying accomplice which inculpate the defendant more than the accomplice are not admissible pursuant to a firmly rooted exception to the hearsay doctrine and thus do not sat

23
Crawford v. Washingtongreen
scotus · 2004 · cited in 6 Pennsylvania opinions naming this issue, 2013–2026
2 sentences

2026Prior to the decision in Crawford, supra, “the United States Supreme Court was of the view the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule or that bore a particularized guarantee of trustworthiness.” Brown, 185 A.3d at 324 , citing Crawford, 541 U.S. at 40 and Ohio v. Roberts, 448 U.S. 56, 66 (1980); see also Commonwealth v. Carter, 932 A.2d 1261 , 1265 n.3 (Pa. 2007).

2016Prior to the United States Supreme Court’s decision in Crawford v. Washington, 541 U.S. 36 (2004), it was generally the view that “the Confrontation Clause did not bar the admission of out-of–court statements that fell within a firmly rooted exception to the hearsay rule." Ohio v. Roberts, 448 U.S. 56 (1980) (abrogated by Crawford).

16
Commonwealth v. Cartergreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026Prior to the decision in Crawford, supra, “the United States Supreme Court was of the view the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule or that bore a particularized guarantee of trustworthiness.” Brown, 185 A.3d at 324 , citing Crawford, 541 U.S. at 40 and Ohio v. Roberts, 448 U.S. 56, 66 (1980); see also Commonwealth v. Carter, 932 A.2d 1261 , 1265 n.3 (Pa. 2007).

11
Commonwealth v. Thomasgreen
pasuperct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023He conceded that the declaration did not fit within a firmly-rooted exception to the hearsay rule, but argued that it was “admissible as substantive evidence because it evinces overwhelming indicia of reliability and trustworthiness.” Id. at 354 (internal citation omitted).

11
cluster 510995green
ca8 · 1988 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
2 sentences

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). [6] Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor's office, both being vested with the task of law e

11
Moore v. Reynoldsgreen
ca10 · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
2 sentences

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir.2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir. 2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

11
Horton v. Allengreen
ca1 · 2004 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
2 sentences

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir.2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir. 2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

11
James Richard Terrovona v. Larry Kincheloegreen
ca9 · 1988 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
2 sentences

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir.2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir. 2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

11
John Francis Hayes v. Michael York, Wardengreen
ca4 · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
2 sentences

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir.2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir. 2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

11
White v. Illinoisgreen
scotus · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
1 sentence

1999See, e.g., Roberts, supra. “[W]here proffered hearsay has sufficient guarantees of reliability to come within a firmly rooted exception to the hearsay rule, the Confrontation Clause is satisfied.” White, supra, at 356 , 112 S.Ct. 736 .

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Ohio v. Robertsred
scotus · 1980 · cited in 7 Pennsylvania opinions naming this issue, 2006–2026
2 sentences

2026Prior to the decision in Crawford, supra, “the United States Supreme Court was of the view the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule or that bore a particularized guarantee of trustworthiness.” Brown, 185 A.3d at 324 , citing Crawford, 541 U.S. at 40 and Ohio v. Roberts, 448 U.S. 56, 66 (1980); see also Commonwealth v. Carter, 932 A.2d 1261 , 1265 n.3 (Pa. 2007).

2016Prior to the United States Supreme Court’s decision in Crawford v. Washington, 541 U.S. 36 (2004), it was generally the view that “the Confrontation Clause did not bar the admission of out-of–court statements that fell within a firmly rooted exception to the hearsay rule." Ohio v. Roberts, 448 U.S. 56 (1980) (abrogated by Crawford).

27

Also cited on this issue (13)

CaseCitedYears
Williams v. Illinois red
scotus · 2012
2 sentences

2014Prior to the decision in Crawford v. Washington, 541 U.S. 36 , [] (2004), the United States Supreme Court took the view that “the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule.” Williams v. Illinois, ––– U.S. ––––, 132 S.Ct. 2221, 2223 , [] (2012); see Ohio v. Roberts, 448 U.S. 56 , [] (1980).

2013Prior to the decision in Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 (2004), the United States Supreme Court took the view that “the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule.” Williams v. Illinois, — U.S. -, 132 S.Ct. 2221, 2223 , 183 L.Ed.2d 89 (2012); see Ohio v. Roberts, 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980).

32013–2014
Commonwealth v. Brown green
pa · 2018
2 sentences

2026Prior to the decision in Crawford, supra, “the United States Supreme Court was of the view the Confrontation Clause did not bar the admission of out-of-court statements that fell within a firmly rooted exception to the hearsay rule or that bore a particularized guarantee of trustworthiness.” Brown, 185 A.3d at 324 , citing Crawford, 541 U.S. at 40 and Ohio v. Roberts, 448 U.S. 56, 66 (1980); see also Commonwealth v. Carter, 932 A.2d 1261 , 1265 n.3 (Pa. 2007).

2026“In Crawford, however, the [High] Court sought to align its Confrontation Clause analysis with the original intent of the framers [of the United States Constitution] who, according to the [High] Court, were concerned about abuses of the civil-law mode of criminal procedure.”14 Brown, 185 A.3d at 324 .

12026–2026
Ernest Kay v. United States green
ca4 · 1958
2 sentences

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). [6] Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor's office, both being vested with the task of law e

12007–2007
State v. Cosgrove green
conn · 1980
2 sentences

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

12007–2007
State v. Kreck green
wash · 1975
2 sentences

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

12007–2007
Howard v. United States green
dc · 1984
2 sentences

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). [6] Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor's office, both being vested with the task of law e

12007–2007
State v. Malsbury green
njsuperctappdiv · 1982
2 sentences

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

2007See, e.g., United States v. Baker, 855 F.2d 1353 (8th Cir.1988); Howard v. United States, 473 A.2d 835 (D.C.App.1984); Kay v. United States, 255 F.2d 476 (4th Cir.1958); State v. Cosgrove, 181 Conn. 562 , 436 A.2d 33 (1980); State v. Malsbury, 186 N.J.Super. 91 , 451 A.2d 421 (Law Div.1982); State v. Kreck, 86 Wash.2d 112 , 542 P.2d 782 (1975). 6 Appellee and the Superior Court majority articulated their concern regarding the possibility of inherent bias by the police lab, as the lab is part of the same branch of government as the prosecutor’s office, both being vested with the task of law enf

12007–2007
United States v. James Saget, Also Known as Hesh green
ca2 · 2004
1 sentence

2006Saget, 377 F.3d at 230 ; see also Roberts, 448 U.S. 56 , 100 S.Ct. 2531 .

12006–2006
Michael Lenza v. Donald W. Wyrick, Warden Attorney General of the State of Missouri green
ca8 · 1981
2 sentences

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir.2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir.2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

12005–2005
Rodney Clay Evans v. Allen Luebbers, Superintendent, Potosi Correctional Center green
ca8 · 2004
2 sentences

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir.2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

2005Horton v. Allen, 370 F.3d 75, 85 (1st Cir.2004); Evans v. Luebbers, 371 F.3d 438 (8th Cir. 2004) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Hayes v. York, 311 F.3d 321, 324-25 (4th Cir.2002); Moore v. Reynolds, 153 F.3d 1086, 1107 (10th Cir.1998) (relying on Lenza v. Wyrick, 665 F.2d 804 (8th Cir.1981)); Terrovona v. Kincheloe, 852 F.2d 424, 427 (9th Cir.1988).

12005–2005
Lilly v. Virginia green
scotus · 1999
2 sentences

2004Young, 748 A.2d at 191 (emphasis added) (construing Lilly, 527 U.S. at 116 , 119 S.Ct. at 1887 ).

2004Young, 748 A.2d at 191 (emphasis added) (construing Lilly, 527 U.S. at 116 , 119 S.Ct. at 1887 ).

12004–2004
Primavera v. Celotex Corp. green
pasuperct · 1992
2 sentences

1999As a panel of this court recognized in Primavera v. Celotex Corp., 415 Pa.Super. 41 , 608 A.2d 515 (1992), appeal denied, 533 Pa. 641 , 622 A.2d 1374 (1993), “The fact that experts reasonably and regularly rely on [out of court] information merely to practice their profession lends strong indicia of reliability to source material, when it is presented through a qualified expert’s eyes.” 608 A.2d at 520 .

1999As a panel of this court recognized in Primavera v. Celotex Corp., 415 Pa.Super. 41 , 608 A.2d 515 (1992), appeal denied, 533 Pa. 641 , 622 A.2d 1374 (1993), “The fact that experts reasonably and regularly rely on [out of court] information merely to practice their profession lends strong indicia of reliability to source material, when it is presented through a qualified expert’s eyes.” 608 A.2d at 520 .

11999–1999
Idaho v. Wright green
scotus · 1990
2 sentences

1990The Wright court cited the excited utterance exception to the hearsay rule as an example of a firmly rooted exception where “the circumstances surrounding the making of the statement provide sufficient assurance that the statement is trustworthy and that cross-examination would be superfluous.” Id.

1990The Wright court cited the excited utterance exception to the hearsay rule as an example of a firmly rooted exception where "the circumstances surrounding the making of the statement provide sufficient assurance that the statement is trustworthy and that cross-examination would be superfluous." Id.

11990–1990

Where else courts name it

TX 47 (1987–2017) OH 30 (1992–2012) CA 22 (1993–2023) VA 21 (1996–2020) IL 20 (1989–2024) NM 17 (1996–2017) WA 17 (1998–2009) CO 17 (1993–2026) PA 15 (1990–2026) NC 14 (1994–2009) LA 12 (1995–2017) AL 12 (1994–2026) FL 11 (1988–2019) MO 11 (1898–2007) MN 10 (1991–2006) AZ 10 (1990–2003) GA 9 (1995–2011) MD 9 (1988–2016) CT 8 (1992–2010) MA 7 (1994–2025) WY 7 (1997–2022) TN 7 (2002–2010) DE 7 (1998–2017) SC 7 (1995–2006) IN 7 (1994–2010) WI 6 (1982–2002) MI 6 (1991–2020) DC 6 (1996–2009) KY 6 (2001–2006) OK 5 (1996–2014) IA 4 (1994–2005) SD 4 (1986–2000) MT 3 (2001–2006) WV 3 (1999–2003) HI 3 (1992–2018) ME 2 (1995–2003) ID 2 (1999–2001) MS 2 (2000–2004) OR 2 (1993–2000) KS 2 (2001–2005) NE 2 (1993–2000) AK 2 (1994–1994)

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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