reliability factors (Iowa) · Go Syfert
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reliability factors in Iowa

13 Iowa opinions name it 2 courts 1979–2022 2 in the last five years

The cases below were cited by Iowa 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 (5)

CaseFollowedCited
Katie Bonner, Esau Bonner v. Isp Technologies, Inc., Crawford & Company, Inc., Movantgreen
ca8 · 2001 · cited in 2 Iowa opinions naming this issue, 2010–2010
2 sentences

2010Dist., 570 N.W.2d 633, 637 (Iowa 1997) (stating that, to be relevant, the evidence must be reliable, and reliability is an implicit requirement of admissibility under Iowa Rule of Evidence 5.702 because “unreliable testimony cannot assist the trier of fact”); see also Bonner v. ISP Techs., Inc., 259 F.3d 924, 929 (8th Cir.2001) (“The rule’s concern with ‘scientific knowledge’ is a reliability requirement, while the requirement that the evidence ‘assist the trier of fact to understand the evidence or determine a fact in issue’ is a relevance requirement.”).

2010Dist., 570 N.W.2d 633, 637 (Iowa 1997) (stating that, to be relevant, the evidence must be reliable, and reliability is an implicit requirement of admissibility under Iowa Rule of Evidence 5.702 because “unreliable testimony cannot assist the trier of fact”); see also Bonner v. ISP Techs., Inc., 259 F.3d 924, 929 (8th Cir. 2001) (“The rule’s concern with ‘scientific knowledge’ is a reliability requirement, while the requirement that the evidence ‘assist the trier of fact to understand the evidence or determine a fact in issue’ is a relevance requirement.”).

22
Johnson v. Knoxville Community School Districtgreen
iowa · 1997 · cited in 2 Iowa opinions naming this issue, 2010–2010
2 sentences

2010Dist., 570 N.W.2d 633, 637 (Iowa 1997) (stating that, to be relevant, the evidence must be reliable, and reliability is an implicit requirement of admissibility under Iowa Rule of Evidence 5.702 because “unreliable testimony cannot assist the trier of fact”); see also Bonner v. ISP Techs., Inc., 259 F.3d 924, 929 (8th Cir.2001) (“The rule’s concern with ‘scientific knowledge’ is a reliability requirement, while the requirement that the evidence ‘assist the trier of fact to understand the evidence or determine a fact in issue’ is a relevance requirement.”).

2010Dist., 570 N.W.2d 633, 637 (Iowa 1997) (stating that, to be relevant, the evidence must be reliable, and reliability is an implicit requirement of admissibility under Iowa Rule of Evidence 5.702 because “unreliable testimony cannot assist the trier of fact”); see also Bonner v. ISP Techs., Inc., 259 F.3d 924, 929 (8th Cir. 2001) (“The rule’s concern with ‘scientific knowledge’ is a reliability requirement, while the requirement that the evidence ‘assist the trier of fact to understand the evidence or determine a fact in issue’ is a relevance requirement.”).

22
State v. Dunngreen
moctapp · 1999 · cited in 2 Iowa opinions naming this issue, 2008–2008
2 sentences

2008As the Tennessee Supreme Court held in Hall , the foundational testimony for non-hearsay evidence need only be provided by a person with “special knowledge about the operation of the computer system.” Hall, 976 S.W.2d at 147 ; see also Dunn, 7 S.W.3d at 432 (holding testimony of a Southwestern Bell employee was sufficient to establish the reliability of records from AT & T).

2008As the Tennessee Supreme Court held in Hall, the foundational testimony for non-hearsay evidence need only be provided by a person with “special knowledge about the operation of the computer system.” Hall, 976 S.W.2d at 147 ; see also Dunn, 7 S.W.3d at 432 (holding testimony of a Southwestern Bell employee was sufficient to establish the reliability of records from AT&T).

22
Neil v. Biggersgreen
scotus · 1972 · cited in 2 Iowa opinions naming this issue, 1979–1981
2 sentences

1981The reliability factors, derived from Neil v. Biggers, 409 U.S. 188, 199 , 93 S.Ct. 375, 382 , 34 L.Ed.2d 401, 411 (1972), include: the opportunity of the witness to view the criminal at the time of the crime, the witness’ degree of attention, the accuracy of the witness’ prior description of the criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation.

1981The reliability factors, derived from Neil v. Biggers, 409 U.S. 188, 199 , 93 S.Ct. 375, 382 , 34 L.Ed.2d 401, 411 (1972), include: the opportunity of the witness to view the criminal at the time of the crime, the witness’ degree of attention, the accuracy of the witness’ prior description of the criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation.

12
Commonwealth v. Johnsongreen
mass · 1995 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020But, as noted by the Supreme Judicial Court of Massachusetts, “[t]he inverse of this is probably more accurate: the admission of unnecessarily suggestive identification procedures under the reliability test would likely result in the innocent being jailed while the guilty remain free.” Johnson, 650 N.E.2d at 1263.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
State v. Legg green
iowa · 2001
2 sentences

2022Id. at 772 .

2022Id. at 772 .

22022–2022
State v. Hall green
tenn · 1998
2 sentences

2008As the Tennessee Supreme Court held in Hall , the foundational testimony for non-hearsay evidence need only be provided by a person with “special knowledge about the operation of the computer system.” Hall, 976 S.W.2d at 147 ; see also Dunn, 7 S.W.3d at 432 (holding testimony of a Southwestern Bell employee was sufficient to establish the reliability of records from AT & T).

2008As the Tennessee Supreme Court held in Hall, the foundational testimony for non-hearsay evidence need only be provided by a person with “special knowledge about the operation of the computer system.” Hall, 976 S.W.2d at 147 ; see also Dunn, 7 S.W.3d at 432 (holding testimony of a Southwestern Bell employee was sufficient to establish the reliability of records from AT&T).

22008–2008
Manson v. Brathwaite green
scotus · 1977
2 sentences

1979The reliability factors to consider are set forth in Biggers, 409 U.S. at 199 , 93 S.Ct. at 382 , 34 L.Ed.2d at 411 , and are repeated in Brathwaite, 432 U.S. at 114 , 97 S.Ct. at 2253 , 53 L.Ed.2d at 154 .

1979The reliability factors to consider are set forth in Biggers, 409 U.S. at 199 , 93 S.Ct. at 382 , 34 L.Ed.2d at 411 , and are repeated in Brathwaite, 432 U.S. at 114 , 97 S.Ct. at 2253 , 53 L.Ed.2d at 154 .

21979–1979
State of Iowa v. Bion Blake Ingram green
iowa · 2018
1 sentence

2020The Doolin dissent noted that through the various cases before the Court, the reliability analysis focused on “a very substantial likelihood of irreparable misidentification.” Id. at ___ (quoting Simmons, 390 U.S. at 384 , 88 S. Ct. at 971 ).

12020–2020
Simmons v. United States green
scotus · 1968
2 sentences

2020The Doolin dissent noted that through the various cases before the Court, the reliability analysis focused on “a very substantial likelihood of irreparable misidentification.” Id. at ___ (quoting Simmons, 390 U.S. at 384 , 88 S. Ct. at 971 ).

2020The Doolin dissent noted that through the various cases before the Court, the reliability analysis focused on “a very substantial likelihood of irreparable misidentification.” Id. at ___ (quoting Simmons, 390 U.S. at 384 , 88 S. Ct. at 971 ).

12020–2020
State v. Long green
utah · 1986
1 sentence

2020It based the factors on “well-respected and essentially unchallenged empirical studies” as laid out in State v. Long, 721 P.2d 483 (Utah 1986), even while conceding that the holding in Long “was not squarely based on the state constitution.” The opinion established this “more empirically based approach” solely because the court “judge[d] this to be a more appropriate approach.” These sorts of considerations—rooted in evolving social science and legal scholarship—may be appropriate grounds for our provision of “guidance” on the reliability of eyewitness identification testimony.

12020–2020
State v. Ramirez green
utah · 1991
1 sentence

2020Id. at 999 (alteration in original) (citations omitted) (quoting Ramirez, 817 P.2d at 780 ).

12020–2020
State v. Reynolds green
iowa · 2008
1 sentence

2018Accordingly, the State agrees on appeal that additional foundation was needed to establish the content of these exhibits did not constitute hearsay. 4 See id. (concluding district court erred in admitting bank statements where “no evidence in the record from any person with knowledge as to how the Federal Reserve error reports were created or as to the reliability of the error reporting system in general”).

12018–2018
Howard v. State green
iowa · 1989
1 sentence

1990Id.

11990–1990
State v. Mark green
iowa · 1979
1 sentence

1981Furthermore, even if we assume the identification procedure is impermissibly suggestive, there is not a very substantial likelihood of irreparable misidentification because the reliability factors discussed in Mark, Id. at 405 are satisfied.

11981–1981

Where else courts name it

TX 398 (1993–2026) OH 82 (1981–2026) IL 82 (1972–2025) CA 64 (1958–2026) NC 60 (1985–2025) NY 54 (1977–2025) WA 54 (1987–2025) MA 41 (1975–2023) FL 40 (1983–2026) TN 37 (1983–2026) CO 37 (1990–2026) VA 34 (1970–2025) MD 32 (1971–2025) NJ 31 (1987–2024) IN 30 (1969–2020) MN 30 (1977–2019) CT 29 (1977–2025) KS 27 (1978–2025) NM 26 (1975–2025) AL 24 (1980–2016) MI 23 (1980–2026) WI 22 (1980–2025) UT 22 (1994–2025) MS 22 (2001–2020) ID 18 (1984–2026) SC 18 (1993–2024) MO 17 (1978–2021) GA 16 (1982–2025) HI 16 (1996–2021) LA 15 (1979–2026) AZ 14 (1975–2024) DC 13 (1977–2025) IA 13 (1979–2022) PA 12 (1981–2025) WV 12 (1990–2024) NH 11 (1967–2024) DE 11 (1996–2025) MT 10 (1994–2019) OR 8 (1982–2022) AK 6 (1979–1996) OK 6 (1991–2019) NE 6 (1994–2022) ME 6 (1979–2026) WY 6 (1993–2025) SD 6 (1936–2022) AR 4 (1981–2026) VT 4 (2000–2024) KY 4 (2006–2019) VI 4 (1999–2016) RI 3 (1989–1999) NV 2 (2005–2013)

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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