Roberts analysis (Idaho) · Go Syfert
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Roberts analysis in Idaho

12 Idaho opinions name it 2 courts 1991–2021 1 in the last five years

The cases below were cited by Idaho 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 (6)

CaseFollowedCited
Mintun v. Stategreen
idahoctapp · 2007 · cited in 2 Idaho opinions naming this issue, 2018–2018
2 sentences

2018Specific to Roberts' claim that his appellate counsel rendered ineffective assistance by not pursuing issues on appeal as fundamental error, the district court dismissed pursuant to Mintun v. State , 144 Idaho 656 , 662, 168 P.3d 40 , 46 (Ct. App. 2007).

2018Specific to Roberts' claim that his appellate counsel rendered ineffective assistance by not pursuing issues on appeal as fundamental error, the district court dismissed pursuant to Mintun v. State , 144 Idaho 656 , 662, 168 P.3d 40 , 46 (Ct. App. 2007).

12
Mitchell James Bias v. Stategreen
idahoctapp · 2015 · cited in 2 Idaho opinions naming this issue, 2018–2018
2 sentences

2018Other claims were dismissed pursuant to Bias v. State , 159 Idaho 696 , 702, 365 P.3d 1050 , 1056 (Ct. App. 2015), on the basis that they were "barred as forfeited because [they] could have been raised on direct appeal." Roberts timely appealed.

2018Other claims were dismissed pursuant to Bias v. State , 159 Idaho 696 , 702, 365 P.3d 1050 , 1056 (Ct. App. 2015), on the basis that they were "barred as forfeited because [they] could have been raised on direct appeal." Roberts timely appealed.

12
State v. Doegreen
idahoctapp · 2004 · cited in 2 Idaho opinions naming this issue, 2006–2008
2 sentences

2008See e.g., State v. Doe, 140 Idaho 873 , 103 P.3d 967 (Ct.App.2004) (assuming, since the Supreme Court had not explicitly overruled Roberts , that nontestimonial statements were still implicated by the Confrontation Clause and applying the Roberts test to statements that were clearly non-testimonial).

2008See e.g., State v. Doe, 140 Idaho 873 , 103 P.3d 967 (Ct.App.2004) (assuming, since the Supreme Court had not explicitly overruled Roberts , that nontestimonial statements were still implicated by the Confrontation Clause and applying the Roberts test to statements that were clearly non-testimonial).

12
PHH Mortgage v. Nickersongreen
idaho · 2018 · cited in 1 Idaho opinions naming this issue, 2021–2021
1 sentence

2021See PHH Mortg., 164 Idaho at 38 , 423 P.3d at 459 .

11
State v. Roygreen
idaho · 1995 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996I.C.R. 52 provides that “[a]ny error, defect, irregularity, or variance which does not affect substantial rights shall be disregarded.” In determining whether an error has affected a defendant’s substantial rights, this Court must ask whether it appears, beyond a reasonable doubt, “that there was no reasonable possibility that the error contributed to the conviction.” State v. Roy, 127 Idaho 228, 231 , 899 P.2d 441, 444 (1995); State v. Sharp, 101 Idaho 498, 507 , 616 P.2d 1034, 1043 (1980). *199 K.H., the oldest of the three witnesses and sixteen at the time of the trial, was the only witness

1996I.C.R. 52 provides that “[a]ny error, defect, irregularity, or variance which does not affect substantial rights shall be disregarded.” In determining whether an error has affected a defendant’s substantial rights, this Court must ask whether it appears, beyond a reasonable doubt, “that there was no reasonable possibility that the error contributed to the conviction.” State v. Roy, 127 Idaho 228, 231 , 899 P.2d 441, 444 (1995); State v. Sharp, 101 Idaho 498, 507 , 616 P.2d 1034, 1043 (1980). *199 K.H., the oldest of the three witnesses and sixteen at the time of the trial, was the only witness

11
State v. Sharpgreen
idaho · 1980 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996I.C.R. 52 provides that “[a]ny error, defect, irregularity, or variance which does not affect substantial rights shall be disregarded.” In determining whether an error has affected a defendant’s substantial rights, this Court must ask whether it appears, beyond a reasonable doubt, “that there was no reasonable possibility that the error contributed to the conviction.” State v. Roy, 127 Idaho 228, 231 , 899 P.2d 441, 444 (1995); State v. Sharp, 101 Idaho 498, 507 , 616 P.2d 1034, 1043 (1980). *199 K.H., the oldest of the three witnesses and sixteen at the time of the trial, was the only witness

1996I.C.R. 52 provides that “[a]ny error, defect, irregularity, or variance which does not affect substantial rights shall be disregarded.” In determining whether an error has affected a defendant’s substantial rights, this Court must ask whether it appears, beyond a reasonable doubt, “that there was no reasonable possibility that the error contributed to the conviction.” State v. Roy, 127 Idaho 228, 231 , 899 P.2d 441, 444 (1995); State v. Sharp, 101 Idaho 498, 507 , 616 P.2d 1034, 1043 (1980). *199 K.H., the oldest of the three witnesses and sixteen at the time of the trial, was the only witness

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (11)

CaseCitedYears
State v. Akin green
idahoctapp · 2003
2 sentences

2017In State v. Akin, 139 Idaho 160 , 75 P.3d 214 (Ct. App. 2003), we held: A declaration of innocence alone does not entitle a defendant to withdraw a guilty plea.

2017In State v. Akin, 139 Idaho 160 , 75 P.3d 214 (Ct. App. 2003), we held: A declaration of innocence alone does not entitle a defendant to withdraw a guilty plea.

12017–2017
State v. Mee green
idaho · 1981
2 sentences

2009Elisondo , however, overruled State v. Mee, 102 Idaho 474 , 632 P.2d 663 (1981), in which the Court had determined that introduction of preliminary hearing testimony was allowable under the Confrontation Clause pursuant to a Roberts analysis. 8 .

2009Elisondo , however, overruled State v. Mee, 102 Idaho 474 , 632 P.2d 663 (1981), in which the Court had determined that introduction of preliminary hearing testimony was allowable under the Confrontation Clause pursuant to a Roberts analysis. 8 .

12009–2009
Whorton v. Bockting green
scotus · 2007
2 sentences

2008Furthermore, as Rolon admits, in a more recent case, Whorton v. Bockting, 549 U.S. 406 , 127 S.Ct. 1173 , 167 L.Ed.2d 1 (2007), the Court again referred to the fact that Roberts had been overruled in regard to nontestimonial statements.

2008Furthermore, as Rolon admits, in a more recent case, Whorton v. Bockting, 549 U.S. 406 , 127 S.Ct. 1173 , 167 L.Ed.2d 1 (2007), the Court again referred to the fact that Roberts had been overruled in regard to nontestimonial statements.

12008–2008
Crawford v. Washington green
scotus · 2004
2 sentences

2006Crawford, 541 U.S. at 59-68 .

2006Crawford, 541 U.S. at 59-68 .

12006–2006
Davis v. Washington green
scotus · 2006
2 sentences

2006In the investigative interrogations at issue in Davis, the Consequently, after finding that the statement in Davis was nontestimonial, the Court did not go on to conduct a Roberts analysis. 4 Court said, “the ex parte actors and the evidentiary products of the ex parte communication aligned perfectly with their courtroom analogues.” Id. at ___, 126 S. Ct. at 2277 .

2006In the investigative interrogations at issue in Davis, the Consequently, after finding that the statement in Davis was nontestimonial, the Court did not go on to conduct a Roberts analysis. 4 Court said, “the ex parte actors and the evidentiary products of the ex parte communication aligned perfectly with their courtroom analogues.” Id. at ___, 126 S. Ct. at 2277 .

12006–2006
White v. Illinois green
scotus · 1992
2 sentences

2004Because this is a firmly rooted hearsay exception, White, 502 U.S. at 355 n. 8, 112 S.Ct. at 742 n. 8, 116 L.Ed.2d at 859 n. 8, the evidence satisfied the Roberts standard and did not violate the Confrontation Clause. 2.

2004Because this is a firmly rooted hearsay exception, White, 502 U.S. at 355 n. 8, 112 S.Ct. at 742 n. 8, 116 L.Ed.2d at 859 n. 8, the evidence satisfied the Roberts standard and did not violate the Confrontation Clause. 2.

12004–2004
State v. Roberts neutral
idahoctapp · 1995
1 sentence

1999Id.

11999–1999
State v. Forde green
idahoctapp · 1987
2 sentences

1995It is well settled that a motion to reduce or to modify an otherwise lawful sentence under Rule 35 is addressed to the sound discretion of the sentencing court, State v. Forde, 113 Idaho 21 , 740 P.2d 63 (Ct.App.1987), and essentially is a plea for leniency which may be granted if the sentence originally imposed was unduly severe.

1995It is well settled that a motion to reduce or to modify an otherwise lawful sentence under Rule 35 is addressed to the sound discretion of the sentencing court, State v. Forde, 113 Idaho 21 , 740 P.2d 63 (Ct.App.1987), and essentially is a plea for leniency which may be granted if the sentence originally imposed was unduly severe.

11995–1995
Mann v. Safeway Stores, Inc. green
idaho · 1974
2 sentences

1991Proximate cause, or contributing proximate cause, is a necessary element of Mrs. Roberts’ claim which she bears the burden of proving at trial. 8 Dreyer v. Zero Refrigeration Lines, Inc., 92 Idaho 83 , 437 P.2d 355 (1968), overruled on other grounds, Mann v. Safeway Stores, Inc., 95 Idaho 732 , 518 P.2d 1194 (1974); Smith v. Sharp, 82 Idaho 420 , 354 P.2d 172 (1960).

1991Proximate cause, or contributing proximate cause, is a necessary element of Mrs. Roberts’ claim which she bears the burden of proving at trial. 8 Dreyer v. Zero Refrigeration Lines, Inc., 92 Idaho 83 , 437 P.2d 355 (1968), overruled on other grounds, Mann v. Safeway Stores, Inc., 95 Idaho 732 , 518 P.2d 1194 (1974); Smith v. Sharp, 82 Idaho 420 , 354 P.2d 172 (1960).

11991–1991
Dreyer v. Zero Refrigeration Lines, Inc. green
idaho · 1968
2 sentences

1991Proximate cause, or contributing proximate cause, is a necessary element of Mrs. Roberts’ claim which she bears the burden of proving at trial. 8 Dreyer v. Zero Refrigeration Lines, Inc., 92 Idaho 83 , 437 P.2d 355 (1968), overruled on other grounds, Mann v. Safeway Stores, Inc., 95 Idaho 732 , 518 P.2d 1194 (1974); Smith v. Sharp, 82 Idaho 420 , 354 P.2d 172 (1960).

1991Proximate cause, or contributing proximate cause, is a necessary element of Mrs. Roberts’ claim which she bears the burden of proving at trial. 8 Dreyer v. Zero Refrigeration Lines, Inc., 92 Idaho 83 , 437 P.2d 355 (1968), overruled on other grounds, Mann v. Safeway Stores, Inc., 95 Idaho 732 , 518 P.2d 1194 (1974); Smith v. Sharp, 82 Idaho 420 , 354 P.2d 172 (1960).

11991–1991
Smith v. Sharp green
idaho · 1960
2 sentences

1991Proximate cause, or contributing proximate cause, is a necessary element of Mrs. Roberts’ claim which she bears the burden of proving at trial. 8 Dreyer v. Zero Refrigeration Lines, Inc., 92 Idaho 83 , 437 P.2d 355 (1968), overruled on other grounds, Mann v. Safeway Stores, Inc., 95 Idaho 732 , 518 P.2d 1194 (1974); Smith v. Sharp, 82 Idaho 420 , 354 P.2d 172 (1960).

1991Proximate cause, or contributing proximate cause, is a necessary element of Mrs. Roberts’ claim which she bears the burden of proving at trial. 8 Dreyer v. Zero Refrigeration Lines, Inc., 92 Idaho 83 , 437 P.2d 355 (1968), overruled on other grounds, Mann v. Safeway Stores, Inc., 95 Idaho 732 , 518 P.2d 1194 (1974); Smith v. Sharp, 82 Idaho 420 , 354 P.2d 172 (1960).

11991–1991

Statutes the citing opinions construe

ID § Idaho Code § 18-1508 (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

TX 40 (1976–2022) CA 38 (1953–2026) GA 29 (1984–2026) WA 29 (1978–2015) FL 28 (1972–2025) OH 24 (1992–2025) CO 18 (1965–2025) IL 18 (1987–2024) PA 17 (1977–2024) OR 17 (1989–2025) NY 14 (1993–2025) NC 13 (1876–2017) ID 12 (1991–2021) KS 12 (1989–2022) HI 11 (1995–2022) VA 11 (1999–2018) MN 10 (1986–2008) MD 9 (1987–2014) MS 9 (1987–2022) WI 9 (1989–2019) UT 8 (2002–2021) CT 8 (1990–2018) AL 8 (1987–2026) NJ 7 (1988–2008) MO 7 (1983–2017) TN 7 (2006–2013) NM 6 (1993–2007) IA 6 (1978–2024) WY 6 (1976–2013) SC 6 (2000–2014) AR 6 (2005–2016) NH 6 (2000–2017) MT 5 (1996–2025) MA 5 (1972–2004) MI 5 (1991–2019) IN 5 (2004–2019) KY 5 (2011–2024) ME 4 (1987–2014) DC 4 (1984–2014) AZ 4 (1986–2006) OK 3 (2002–2004) LA 2 (1989–2008) NV 2 (1998–2018) RI 2 (2010–2013)

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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