spontaneous utterance exception (District of Columbia) · Go Syfert
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spontaneous utterance exception in District of Columbia

13 District of Columbia opinions name it 1 courts 1978–2011 0 in the last five years

The cases below were cited by District of Columbia 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 (14)

CaseFollowedCited
Nicholson v. United Statesgreen
dc · 1977 · cited in 7 District of Columbia opinions naming this issue, 1978–2007
2 sentences

2007See, e.g., Nicholson, supra, 368 A.2d at 564-65 (concluding that declarant’s response to “what in the world happened,” asked minutes after the declarant was stabbed, was admissible under the spontaneous utterance exception).

2007See, e.g., Nicholson, supra, 368 A.2d at 564-65 (concluding that declarant’s response to “what in the world happened,” asked minutes after the declarant was stabbed, was admissible under the spontaneous utterance exception).

77
Alston v. United Statesgreen
dc · 1983 · cited in 3 District of Columbia opinions naming this issue, 1992–1996
2 sentences

1996See Alston v. United States, supra, 462 A.2d at 1127 (“when the utterance is made immediately after the disturbing incident ... or a few minutes after the incident,” it fits within the spontaneous utterance exception (citations omitted)).

1994See Alston v. United States, supra, 462 A.2d at 1127 (“when the utterance is made immediately after the disturbing incident ... or a few minutes after the incident,” it fits within the spontaneous utterance exception) (citations omitted)).

33
White v. Illinoisgreen
scotus · 1992 · cited in 2 District of Columbia opinions naming this issue, 1996–1998
2 sentences

1998See White v. Illinois, 502 U.S. 346 , 112 S.Ct. 736 , 116 L.Ed.2d 848 (1992).” Woodfolk, supra, 656 A.2d at 1151 n. 17.

1998See White v. Illinois, 502 U.S. 346 , 112 S.Ct. 736 , 116 L.Ed.2d 848 (1992).” Woodfolk, supra, 656 A.2d at 1151 n. 17.

22
Moore v. United Statesgreen
dc · 2007 · cited in 1 District of Columbia opinions naming this issue, 2011–2011
1 sentence

2011Moore v. United States, 927 A.2d 1040, 1049 (D.C.2007) (quoting Curty v. United States, 520 A.2d 255, 263 (D.C.1987)). 40 .

11
Curry v. United Statesgreen
dc · 1987 · cited in 1 District of Columbia opinions naming this issue, 2011–2011
1 sentence

2011Moore v. United States, 927 A.2d 1040, 1049 (D.C.2007) (quoting Curty v. United States, 520 A.2d 255, 263 (D.C.1987)). 40 .

11
Carter v. United Statesgreen
dc · 1992 · cited in 1 District of Columbia opinions naming this issue, 2011–2011
1 sentence

2011See Reyes v. United States, 933 A.2d 785 , 793 n. 10 (D.C.2007) (stating that even if trial court erred in admitting officer's testimony under the spontaneous utterance exception, it was harmless because it was mostly cumulative of other testimony); Carter v. United States, 614 A.2d 542, 545 (D.C.1992) (finding erroneously admitted hearsay used to impeach appellant's testimony harmless because it was only cumulative given impeachment through properly admitted evidence and because other evidence showed appellant's guilt). 39 .

11
Reyes v. United Statesgreen
dc · 2007 · cited in 1 District of Columbia opinions naming this issue, 2011–2011
1 sentence

2011See Reyes v. United States, 933 A.2d 785 , 793 n. 10 (D.C.2007) (stating that even if trial court erred in admitting officer's testimony under the spontaneous utterance exception, it was harmless because it was mostly cumulative of other testimony); Carter v. United States, 614 A.2d 542, 545 (D.C.1992) (finding erroneously admitted hearsay used to impeach appellant's testimony harmless because it was only cumulative given impeachment through properly admitted evidence and because other evidence showed appellant's guilt). 39 .

11
Smith v. United Statesgreen
dc · 1995 · cited in 1 District of Columbia opinions naming this issue, 2007–2007
1 sentence

2007See Smith v. United States, 666 A.2d 1216, 1222 (D.C.1995) (quoting Nicholson v. United States, 368 A.2d 561, 564 (D.C.1977)). 6 “Whether a statement constitutes a spontaneous utterance depends upon the particular facts of each case, and its admissibility as such is committed to the sound discretion of the court.” Id. (citations omitted).

11
Brown v. United Statesgreen
dc · 2004 · cited in 1 District of Columbia opinions naming this issue, 2007–2007
1 sentence

2007See Brown v. United States, 840 A.2d 82, 89 (D.C.2004).

11
Coates v. United Statesgreen
dc · 1998 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
1 sentence

2003See Coates v. United States, 705 A.2d 1100, 1104 (D.C.1998) (setting forth the plain error standard); Malloy v. United States, 797 A.2d 687, 689-90 (D.C.2002) (statement by witness to a crime admitted under the spontaneous utterance exception to the hearsay rule).

11
Malloy v. United Statesgreen
dc · 2002 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
1 sentence

2003See Coates v. United States, 705 A.2d 1100, 1104 (D.C.1998) (setting forth the plain error standard); Malloy v. United States, 797 A.2d 687, 689-90 (D.C.2002) (statement by witness to a crime admitted under the spontaneous utterance exception to the hearsay rule).

11
Commonwealth v. Wheltongreen
mass · 1998 · cited in 1 District of Columbia opinions naming this issue, 1998–1998
2 sentences

1998Commonwealth v. Whelton, 428 Mass. 24 , 696 N.E.2d 540, 545 (Mass.1998).

1998Commonwealth v. Whelton, 428 Mass. 24 , 696 N.E.2d 540, 545 (Mass.1998).

11
United States v. Woodfolkgreen
dc · 1995 · cited in 1 District of Columbia opinions naming this issue, 1998–1998
2 sentences

1998See White v. Illinois, 502 U.S. 346 , 112 S.Ct. 736 , 116 L.Ed.2d 848 (1992).” Woodfolk, supra, 656 A.2d at 1151 n. 17.

1998See White v. Illinois, 502 U.S. 346 , 112 S.Ct. 736 , 116 L.Ed.2d 848 (1992).” Woodfolk, supra, 656 A.2d at 1151 n. 17.

11
Price v. United Statesgreen
dc · 1988 · cited in 1 District of Columbia opinions naming this issue, 1990–1990
1 sentence

1990See Price v. United States, 545 A.2d 1219, 1226 (D.C.1988), and cases cited.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
James v. United States green
dc · 1990
1 sentence

1995Id. at 638-1 .

11995–1995
Beausoliel v. United States green
cadc · 1939
1 sentence

1983Fitzgerald v. United States, supra, 412 A.2d at 9 ; Beausoliel v. United States, supra, 71 U.S.App.D.C. at 114, 107 F.2d at 295 .

11983–1983
Fitzgerald v. United States green
dc · 1980
1 sentence

1983Fitzgerald v. United States, supra, 412 A.2d at 9 ; Beausoliel v. United States, supra, 71 U.S.App.D.C. at 114, 107 F.2d at 295 .

11983–1983

Statutes the citing opinions construe

DC § D.C. Code § 22-2403 (5) DC § D.C. Code § 22-2801 (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

CT 41 (1974–2025) MA 36 (1983–2023) DC 13 (1978–2011) RI 11 (1978–1997) TX 7 (1979–2008) CA 5 (2005–2015) IL 3 (1980–1993) MI 2 (1973–1982) VA 2 (1986–1988) MO 2 (1984–1986) AZ 2 (1978–1995)

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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