14 Minnesota opinions name it 2 courts 2005–2018 0 in the last five years
The cases below were cited by Minnesota 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.
| Case | Followed | Cited |
|---|---|---|
State v. Goodridgegreen2 sentences2018Where ... that speaker is the defendant, the Sixth Amendment simply has no application because a defendant cannot complain that he was denied the opportunity to confront himself. 679 F.3d 1131 , 1140 (9th Cir. 2012) ; see also State v. Goodridge , 352 N.W.2d 384 , 388 n.2 (Minn. 1984) ("[A] party cannot object to his failure to have a chance to cross-examine himself."). 2018Where ... that speaker is the defendant, the Sixth Amendment simply has no application because a defendant cannot complain that he was denied the opportunity to confront himself. 679 F.3d 1131 , 1140 (9th Cir. 2012) ; see also State v. Goodridge , 352 N.W.2d 384 , 388 n.2 (Minn. 1984) ("[A] party cannot object to his failure to have a chance to cross-examine himself."). | 1 | 1 |
Danforth v. Stategreen2 sentences2009Danforth v. State, 718 N.W.2d 451, 455-56, 461 (Minn.2006). 2009Danforth v. State, 718 N.W.2d 451, 455-56, 461 (Minn.2006). | 1 | 1 |
State v. Weavergreen1 sentence2008Id. at 799. | 1 | 1 |
State v. Grubegreen2 sentences2007See State v. Grabe, 531 N.W.2d 484, 489-90 (Minn.1995) (determining, under the pre-Crawford standard, that affidavits in support of murder victim’s OFP were sufficiently trustworthy to avoid violation of the Confrontation Clause); State v. Bradford, 618 N.W.2d 782, 797-98 (Minn.2000) (concluding that the record provided too little information to determine whether affidavits in support of an OFP were sufficiently trustworthy to satisfy hearsay rules, but that any error made in the admission of the affidavits at trial was harmless). 2007See State v. Grube, 531 N.W.2d 484, 489-90 (Minn.1995) (determining, under the pre- Crawford standard, that affidavits in support of murder victim's OFP were sufficiently trustworthy to avoid violation of the Confrontation Clause); State v. Bradford, 618 N.W.2d 782, 797-98 (Minn. 2000) (concluding that the record provided too little information to determine whether affidavits in support of an OFP were sufficiently trustworthy to satisfy hearsay rules, but that any error made in the admission of the affidavits at trial was harmless). | 1 | 1 |
State v. Bradfordgreen2 sentences2007See State v. Grabe, 531 N.W.2d 484, 489-90 (Minn.1995) (determining, under the pre-Crawford standard, that affidavits in support of murder victim’s OFP were sufficiently trustworthy to avoid violation of the Confrontation Clause); State v. Bradford, 618 N.W.2d 782, 797-98 (Minn.2000) (concluding that the record provided too little information to determine whether affidavits in support of an OFP were sufficiently trustworthy to satisfy hearsay rules, but that any error made in the admission of the affidavits at trial was harmless). 2007See State v. Grube, 531 N.W.2d 484, 489-90 (Minn.1995) (determining, under the pre- Crawford standard, that affidavits in support of murder victim's OFP were sufficiently trustworthy to avoid violation of the Confrontation Clause); State v. Bradford, 618 N.W.2d 782, 797-98 (Minn. 2000) (concluding that the record provided too little information to determine whether affidavits in support of an OFP were sufficiently trustworthy to satisfy hearsay rules, but that any error made in the admission of the affidavits at trial was harmless). | 1 | 1 |
State v. Juarezgreen1 sentence2006We recently applied harmless error analysis to Crawford error and found such error harmless beyond a reasonable doubt if “the guilty verdict actually rendered was ‘surely unattributable’ to the error.” State v. Courtney, 696 N.W.2d 73, 79-80 (Minn.2005) (quoting State v. Juarez, 572 N.W.2d 286, 292 (Minn.1997)). | 1 | 1 |
State v. Wrightgreen1 sentence2006Both Bobadilla and Scacchetti determine whether statements made by three-year-old victims of sexual abuse are testimonial by considering factors articulated in State v. Wright, 701 N.W.2d 802, 812-13 (Minn.2005), and applying the overall principle that a “substantial purpose” of the testimonial statement is “producing evidence for trial.” Bobadilla, 709 N.W.2d at 252 ; see Scacchetti, 711 N.W.2d at 513 . | 1 | 1 |
State v. Courtneygreen1 sentence2006We recently applied harmless error analysis to Crawford error and found such error harmless beyond a reasonable doubt if “the guilty verdict actually rendered was ‘surely unattributable’ to the error.” State v. Courtney, 696 N.W.2d 73, 79-80 (Minn.2005) (quoting State v. Juarez, 572 N.W.2d 286, 292 (Minn.1997)). | 1 | 1 |
State v. Martingreen2 sentences2006State v. Martin, 695 N.W.2d 578, 584-86 (Minn.2005). 2006State v. Martin, 695 N.W.2d 578, 584-86 (Minn.2005). | 1 | 1 |
State v. Scacchettigreen2 sentences2006It vacated section I of this court’s May 24, 2005 opinion, with instructions to reconsider the Crawford issue in light of the supreme court’s opinions in State v. Bobadilla, 709 N.W.2d 243 (Minn.2006), and State v. Scacchetti, 711 N.W.2d 508 (Minn.2006). 2006Both Bobadilla and Scacchetti determine whether statements made by three-year-old victims of sexual abuse are testimonial by considering factors articulated in State v. Wright, 701 N.W.2d 802, 812-13 (Minn.2005), and applying the overall principle that a “substantial purpose” of the testimonial statement is “producing evidence for trial.” Bobadilla, 709 N.W.2d at 252 ; see Scacchetti, 711 N.W.2d at 513 . | 1 | 1 |
UNITED STATES of America, Appellee, v. Emery Joseph BEAULIEU, Also Known as Joe Beaulieu, Appellantgreen1 sentence2005See United States v. Beaulieu, 194 F.3d 918, 921 (8th Cir.1999) (stating pre- Crawford rule of admissibility requiring that medical interviewer "makes clear to the victim that the inquiry into the identity of the abuser is important to diagnosis and treatment"). [4] The authors add a category of non-testimonial statements that begs for interpretation, a statement made "with no recognition that it relates to criminal activity." Friedman, supra at 1241 n. 276. | 1 | 1 |
JEFFREY R. FERGUSON, — v. DONALD P. ROPER, —green1 sentence2005Finally, Evans found that Crawford would not apply retroactively because “the Crawford court did not suggest that this doctrine would apply retroactively and the doctrine itself does not appear to fall within either of the two narrow exceptions to Teague v. Lane’s non-retroactivity doctrine.” Evans, 371 F.3d at 444 ; see also Ferguson v. Roper, 400 F.3d 635 , 639 n. 3 (8th Cir.2005) (citing Evans for proposition that Crawford doctrine does not fall within Teague exceptions). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Crawford v. Washington
green
2 sentences2009Similarly, when Danforth sought the protection of the rule announced in Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 (2004), regarding admissibility of certain out-of-court testimonial statements under the Sixth Amendment’s Confrontation Clause, we stated that we were required to apply Teague and held that Danforth was not entitled to retroactive application of the new Crawford rule. 2009Similarly, when Danforth sought the protection of the rule announced in Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 (2004), regarding admissibility of certain out-of-court testimonial statements under the Sixth Amendment’s Confrontation Clause, we stated that we were required to apply Teague and held that Danforth was not entitled to retroactive application of the new Crawford rule. | 2 | 2009–2009 |
Teague v. Lane
green
2 sentences2006Danforth argues that this court is free to apply a broader retroactivity standard than that of Teague v. Lane, 489 U.S. 288 , 109 S.Ct. 1060 , 103 L.Ed.2d 334 (1989), and that he is entitled to the benefit of Crawford under state retroactivity principles. 2006Danforth argues that this court is free to apply a broader retroactivity standard than that of Teague v. Lane, 489 U.S. 288 , 109 S.Ct. 1060 , 103 L.Ed.2d 334 (1989), and that he is entitled to the benefit of Crawford under state retroactivity principles. | 2 | 2006–2006 |
United States v. Manoel Rodriguez Da Silva
green
1 sentence2018The court in Nazemian noted that other federal circuit courts of appeal take the view that an interpreter under "some circumstances [should] be viewed as an agent of the defendant, and the translation hence be attributable to the defendant as her own admission." Id . at 526 (citing United States v. Da Silva , 725 F.2d 828 , 831-32 (2d Cir. 1983) (holding that when agency relationship between speaker and interpreter may properly be found to exist, interpreter becomes no more than a "language conduit" and the "testimonial identity between declarant and translator brings the declarant's admission | 1 | 2018–2018 |
United States v. Orm Hieng
green
2 sentences2018Where ... that speaker is the defendant, the Sixth Amendment simply has no application because a defendant cannot complain that he was denied the opportunity to confront himself. 679 F.3d 1131 , 1140 (9th Cir. 2012) ; see also State v. Goodridge , 352 N.W.2d 384 , 388 n.2 (Minn. 1984) ("[A] party cannot object to his failure to have a chance to cross-examine himself."). 2018Where ... that speaker is the defendant, the Sixth Amendment simply has no application because a defendant cannot complain that he was denied the opportunity to confront himself. 679 F.3d 1131 , 1140 (9th Cir. 2012) ; see also State v. Goodridge , 352 N.W.2d 384 , 388 n.2 (Minn. 1984) ("[A] party cannot object to his failure to have a chance to cross-examine himself."). | 1 | 2018–2018 |
Davis v. Washington
green
2 sentences2009In Davis v. Washington, 547 U.S. 813, 822 , 126 S.Ct. 2266 , 165 L.Ed.2d 224 (2006), the Supreme Court revisited Crawford and established guidelines for determining when statements made to police are testimonial. 2009In Davis v. Washington, 547 U.S. 813, 822 , 126 S.Ct. 2266 , 165 L.Ed.2d 224 (2006), the Supreme Court revisited Crawford and established guidelines for determining when statements made to police are testimonial. | 1 | 2009–2009 |
State v. Houston
green
1 sentence2006Given the pre-existing Confrontation Clause protections for defendants under Roberts, Crawford’s rule is not “essential to the fundamental fairness of a proceeding.” Houston, 702 N.W.2d at 273 . | 1 | 2006–2006 |
Williamson v. United States
green
2 sentences2006Jihad argued on direct appeal that the statement at issue was not truly self-inculpatory and therefore admission of the statement violated the rule in Williamson v. United States, 512 U.S. 594 , 114 S.Ct. 2431 , 129 L.Ed.2d 476 (1994). 2006Jihad argued on direct appeal that the statement at issue was not truly self-inculpatory and therefore admission of the statement violated the rule in Williamson v. United States, 512 U.S. 594 , 114 S.Ct. 2431 , 129 L.Ed.2d 476 (1994). | 1 | 2006–2006 |
State v. Bobadilla
green
2 sentences2006It vacated section I of this court’s May 24, 2005 opinion, with instructions to reconsider the Crawford issue in light of the supreme court’s opinions in State v. Bobadilla, 709 N.W.2d 243 (Minn.2006), and State v. Scacchetti, 711 N.W.2d 508 (Minn.2006). 2006Both Bobadilla and Scacchetti determine whether statements made by three-year-old victims of sexual abuse are testimonial by considering factors articulated in State v. Wright, 701 N.W.2d 802, 812-13 (Minn.2005), and applying the overall principle that a “substantial purpose” of the testimonial statement is “producing evidence for trial.” Bobadilla, 709 N.W.2d at 252 ; see Scacchetti, 711 N.W.2d at 513 . | 1 | 2006–2006 |
People v. Fry
green
2 sentences2005Hannon relies on a decision of the Colorado Supreme Court, People v. Fry, 92 P.3d 970 (Colo.2004), to support the proposition that the Crawford exception requires an adequate cross-examination. 2005Hannon relies on a decision of the Colorado Supreme Court, People v. Fry, 92 P.3d 970 (Colo.2004), to support the proposition that the Crawford exception requires an adequate cross-examination. | 1 | 2005–2005 |
Rodney Clay Evans v. Allen Luebbers, Superintendent, Potosi Correctional Center
green
1 sentence2005Finally, Evans found that Crawford would not apply retroactively because “the Crawford court did not suggest that this doctrine would apply retroactively and the doctrine itself does not appear to fall within either of the two narrow exceptions to Teague v. Lane’s non-retroactivity doctrine.” Evans, 371 F.3d at 444 ; see also Ferguson v. Roper, 400 F.3d 635 , 639 n. 3 (8th Cir.2005) (citing Evans for proposition that Crawford doctrine does not fall within Teague exceptions). | 1 | 2005–2005 |
Diane M. Hendricks Kenneth A. Hendricks v. Bank of America, N.A., and Mutual Indemnity (Bermuda), Ltd., a Bermuda Corporation
green
1 sentence2005Only the ninth circuit, in Bockting v. Bayer, 399 F.3d 1010 (9th Cir.2005), amended by 408 F.3d 1127 (9th Cir.2005), has held that Crawford applies retroactively. | 1 | 2005–2005 |
Marvin Howard Bockting v. Robert Bayer
green
1 sentence2005Only the ninth circuit, in Bockting v. Bayer, 399 F.3d 1010 (9th Cir.2005), amended by 408 F.3d 1127 (9th Cir.2005), has held that Crawford applies retroactively. | 1 | 2005–2005 |
State v. Burrell
green
2 sentences2005Id. at 586-87 , *310 590-91. 2005Id. at 586-87 , *310 590-91. | 1 | 2005–2005 |
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.
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.