public records exception (Arizona) · Go Syfert
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public records exception in Arizona

11 Arizona opinions name it 1 courts 1989–2022 1 in the last five years

The cases below were cited by Arizona 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
Dancing Sunshines Lounge v. Industrial Commissiongreen
ariz · 1986 · cited in 2 Arizona opinions naming this issue, 2019–2020
2 sentences

2020Comm’n, 149 Ariz. 480, 483 (1986). ¶40 The State’s motion for partial summary judgment informed Judge Udall that the State had previously sought dismissal of the public records claim but that Judge Ronan had not resolved the matter.

2019Comm’n, 149 Ariz. 480, 483 (1986). ¶39 The State’s motion for partial summary judgment informed Judge Udall that the State previously sought dismissal of the public records claim but that Judge Ronan did not resolve the matter.

22
State of Arizona v. Javier Solisgreen
arizctapp · 2014 · cited in 1 Arizona opinions naming this issue, 2022–2022
1 sentence

2022Bennett, 216 Ariz. at 16 , 18 ¶¶ 1, 8; see also State v. Solis, 236 Ariz. 242 , 246 ¶ 11 (App. 2014) (in-state exemplification incorporates attached documents as being true and correct copies). ¶17 Cawthon argues, however, that even assuming the pen pack was a self-authenticated document, it did not fall under the public records exception because the “source of the information or other circumstances indicate a lack of trustworthiness,” citing Rule 803(8)(b).

11
Hudgins v. SOUTHWEST AIRLINES, CO.green
arizctapp · 2009 · cited in 1 Arizona opinions naming this issue, 2015–2015
2 sentences

2015Airlines, Co., 221 Ariz. 472 , 484 ¶ 31, 212 P.3d 810, 822 (App. 2009) (providing that reports reflecting matters a public official observed or heard and reported pursuant to his duties are admissible in civil cases pursuant to Rule 803(8)(B), the public records exception to the hearsay rule).

2015Airlines, Co., 221 Ariz. 472 , 484 ¶ 31, 212 P.3d 810, 822 (App. 2009) (providing that reports reflecting matters a public official observed or heard and reported pursuant to his duties are admissible in civil cases pursuant to Rule 803(8)(B), the public records exception to the hearsay rule).

11
William A. BROWN, M.D., Plaintiff-Appellant, v. SIERRA NEVADA MEMORIAL MINERS HOSPITAL, Et Al., Defendants-Appelleesgreen
ca9 · 1988 · cited in 1 Arizona opinions naming this issue, 1994–1994
1 sentence

1994See Brown v. Sierra Nevada Memorial Miners Hosp., 849 F.2d 1186, 1190 (9th Cir.1988) (the assumption supporting the public records exception, that an administrative body’s findings are trustworthy, is substantially weakened when extended to sources outside the agency from which the agency culls the information for its report).

11
Mathis v. Philadelphia Newspapers, Inc.green
paed · 1978 · cited in 1 Arizona opinions naming this issue, 1989–1989
1 sentence

1989Mathis v. Philadelphia Newspa pers, Inc., 455 F.Supp. 406, 417 (E.D.Pa.1978) (affirming summary judgment for defendant newspaper where reporters had relied on an FBI report that incorrectly included the plaintiffs photograph).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
United States v. Paul v. Oates green
ca2 · 1977
2 sentences

2006Therefore, we must determine whether the QARs, although statutorily characterized as public records under § 28-1323(A)(5), are nonetheless inadmissible under Rule 803(8)(B). ¶38 Bohsancurt cites United States v. Oates, 560 F.2d 45 (2d Cir.1977), in which the court concluded that chemists of the United States Customs Service were law enforcement personnel and, therefore, that their reports could not be admitted under the public records exception.

2006Therefore, we must determine whether the QARs, although statutorily characterized as public records under § 28- 1323(A)(5), are nonetheless inadmissible under Rule 803(8)(B). 23 ¶38 Bohsancurt cites United States v. Oates, 560 F.2d 45 (2d Cir. 1977), in which the court concluded that chemists of the United States Customs Service were law enforcement personnel and, therefore, that their reports could not be admitted under the public records exception.

22006–2006
State v. Bennett green
arizctapp · 2007
1 sentence

2022Bennett, 216 Ariz. at 16 , 18 ¶¶ 1, 8; see also State v. Solis, 236 Ariz. 242 , 246 ¶ 11 (App. 2014) (in-state exemplification incorporates attached documents as being true and correct copies). ¶17 Cawthon argues, however, that even assuming the pen pack was a self-authenticated document, it did not fall under the public records exception because the “source of the information or other circumstances indicate a lack of trustworthiness,” citing Rule 803(8)(b).

12022–2022
cluster 751858 green
ca5 · 1998
1 sentence

2009SWA argues the trial court erred in denying the motion in limine because (1) the public records exception does not apply to preliminary reports like the reports at issue, and (2) the March 15 report lacked trustworthiness. ¶ 30 To support its first contention, SWA relies on Smith v. Isuzu Motors, Ltd., 137 F.3d 859 , 862 (5th Cir.1998), which held that an agency’s interim reports or preliminary memoranda did not fall within the public records exception as embodied by Federal Rule of Evidence 803(8)(C).

12009–2009
Woodward v. United States green
scotus · 2000
2 sentences

2003Id. at 1086-87 . “[D]istrict courts should admit such law-enforcement reports, if at all, only under the public-records exception contained in Federal Rule of Evidence 803(8).” Id. (citing United States v. Orozco, 590 F.2d 780, 793 (9th Cir.1979)).

2003Id. at 1086-87 . “[D]istrict courts should admit such law-enforcement reports, if at all, only under the public-records exception contained in Federal Rule of Evidence 803(8).” Id. (citing United States v. Orozco, 590 F.2d 780, 793 (9th Cir.1979)).

12003–2003
Berry v. State, Dept. of Corrections green
arizctapp · 1985
2 sentences

1996Berry v. Dept. of Corrections, 145 Ariz. 12 , 699 P.2d 387 (App.1985).

1996Berry v. Dept. of Corrections, 145 Ariz. 12 , 699 P.2d 387 (App.1985).

11996–1996

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 39-121 (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

LA 119 (1957–2025) OH 65 (1991–2026) TX 43 (1983–2026) FL 42 (1971–2025) IN 21 (1982–2024) CA 20 (1994–2026) WA 18 (1984–2026) PA 18 (1971–2025) IL 16 (1978–2024) NM 15 (1995–2020) MI 11 (1992–2025) AZ 11 (1989–2022) WI 10 (1998–2025) NJ 10 (2002–2024) MA 8 (1985–2025) AK 8 (1988–2025) DC 7 (1991–2009) MD 7 (1990–2018) TN 6 (1999–2018) NC 6 (2006–2026) ID 6 (1990–2026) OR 6 (1992–2025) HI 5 (1996–2019) ME 5 (1984–2022) NV 5 (2014–2017) GA 5 (1998–2016) MS 4 (2003–2021) IA 4 (1982–2025) SD 4 (2004–2026) OK 4 (1936–2014) CO 4 (1987–2015) VA 3 (2003–2019) SC 3 (2008–2014) NY 3 (2007–2010) CT 2 (1970–1997) UT 2 (1987–2017) AL 2 (2000–2000) VT 2 (2000–2026) NE 2 (1938–2013) ND 2 (2009–2013) WV 2 (1999–2002) MN 2 (1984–2024) DE 2 (1986–2001)

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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