residual exception (Arizona) · Go Syfert
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residual exception in Arizona

11 Arizona opinions name it 2 courts 1974–2024 3 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 (6)

CaseFollowedCited
State of Arizona v. Johnathan Ian Burnsgreen
ariz · 2015 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024In deciding whether a statement is sufficiently trustworthy under the residual exception, courts “consider ‘the spontaneity, consistency, knowledge, and motives of the declarant . . . to speak truthfully,’ among other things.” Burns, 237 Ariz. at 20, ¶ 69 (citation omitted).

11
State v. Geeslingreen
ariz · 2010 · cited in 1 Arizona opinions naming this issue, 2014–2014
2 sentences

2014See Geeslin, 223 Ariz. 553, ¶ 5 , 225 P.3d at 1130 .

2014See Geeslin, 223 Ariz. 553, ¶ 5 , 225 P.3d at 1130 .

11
Helen L. Huff, Administratrix of the Estate of Jessee Huff, Deceased, Cross-Appellant v. White Motor Corporation, Cross-Appelleegreen
ca7 · 1979 · cited in 1 Arizona opinions naming this issue, 1988–1988
1 sentence

1988Some courts have flatly stated that “The probability that the statement is true, as shown by corroborative evidence, is not, we think, a consideration relevant to its admissibility under the residual exception to the hearsay rule.” Huff v. White Motor Corp., 609 F.2d 286, 292 (7th Cir.1979); accord State v. Ryan, 103 Wash.2d 165, 174 , 691 P.2d 197, 204 (1984).

11
State v. Ryangreen
wash · 1984 · cited in 1 Arizona opinions naming this issue, 1988–1988
2 sentences

1988Some courts have flatly stated that “The probability that the statement is true, as shown by corroborative evidence, is not, we think, a consideration relevant to its admissibility under the residual exception to the hearsay rule.” Huff v. White Motor Corp., 609 F.2d 286, 292 (7th Cir.1979); accord State v. Ryan, 103 Wash.2d 165, 174 , 691 P.2d 197, 204 (1984).

1988Some courts have flatly stated that “The probability that the statement is true, as shown by corroborative evidence, is not, we think, a consideration relevant to its admissibility under the residual exception to the hearsay rule.” Huff v. White Motor Corp., 609 F.2d 286, 292 (7th Cir.1979); accord State v. Ryan, 103 Wash.2d 165, 174 , 691 P.2d 197, 204 (1984).

11
State v. Sprattgreen
arizctapp · 1980 · cited in 1 Arizona opinions naming this issue, 1983–1983
2 sentences

1983In State v. Spratt, 126 Ariz. 184, 187 , 613 P.2d 848, 851 (App. 1980), our Court of Appeals held that a defendant's out of court assertion of his innocence lacked equivalent sufficient circumstantial guarantees of trustworthiness to make it admissible under the residual exception of Rule 803(24), and therefore the statement was properly excluded.

1983In State v. Spratt, 126 Ariz. 184, 187 , 613 P.2d 848, 851 (App. 1980), our Court of Appeals held that a defendant's out of court assertion of his innocence lacked equivalent sufficient circumstantial guarantees of trustworthiness to make it admissible under the residual exception of Rule 803(24), and therefore the statement was properly excluded.

11
State v. Duffygreen
arizctapp · 1979 · cited in 1 Arizona opinions naming this issue, 1983–1983
2 sentences

1983Similarly in State v. Duffy, 124 Ariz. 267, 275 , 603 P.2d 538, 546 (App. 1979), the court held that the trustworthiness of defendant's self-serving our of court statements was "highly suspect," and therefore the trial court properly denied their admissibility.

1983Similarly in State v. Duffy, 124 Ariz. 267, 275 , 603 P.2d 538, 546 (App. 1979), the court held that the trustworthiness of defendant's self-serving our of court statements was "highly suspect," and therefore the trial court properly denied their admissibility.

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 (6)

CaseCitedYears
State v. Adamson green
ariz · 1983
2 sentences

2024The court ruled that, based on the circumstances surrounding the hospital interviews, John’s statements were admissible as dying declarations under State v. Adamson, 136 Ariz. 250 (1983), and also under the residual exception in Rule 807 of the Arizona Rules of Evidence.

1992Id. at 812 .

21992–2024
State of Arizona v. James Clayton Johnson green
ariz · 2019
2 sentences

2024Johnson, 247 Ariz. at 185 ¶ 41. ¶82 Under the residual exception to hearsay, a hearsay statement that is not admissible under an exception in Rule 803 or 804 is not excluded by the rule against hearsay if: “(1) the statement is supported by sufficient guarantees of trustworthiness—after considering the totality of circumstances under which it was made and evidence, if any, corroborating the statement;” and “(2) it is more probative on the point for which it is offered than any other evidence that the proponent can obtain through reasonable efforts.” Ariz. R.

2024Johnson, 247 Ariz. at 185 ¶ 41. ¶82 Under the residual exception to hearsay, a hearsay statement that is not admissible under an exception in Rule 803 or 804 is not excluded by the rule against hearsay if: “(1) the statement is supported by sufficient guarantees of trustworthiness—after considering the totality of circumstances under which it was made and evidence, if any, corroborating the statement;” and “(2) it is more probative on the point for which it is offered than any other evidence that the proponent can obtain through reasonable efforts.” Ariz. R.

12024–2024
Dallas County v. Commercial Union Assurance Company, Ltd. green
ca5 · 1961
1 sentence

1994The Senate Committee reported that it adopted the residual exception “[b]ecause exceptional eases like the Dallas County case may arise in the future----” Udall et al., supra, at 557 .

11994–1994
State v. Robinson green
ariz · 1987
2 sentences

1991Robinson, 153 Ariz. at 202 , 735 P.2d at 812 .

1991Robinson, 153 Ariz. at 202 , 735 P.2d at 812 .

11991–1991
Sloan v. Florida-Vanderbilt Development Corp. green
arizctapp · 1974
2 sentences

1980Sloan v. Florida-Vanderbilt Development Corp., 22 Ariz.App. 572 , 529 P.2d 726 (1974).

1980Sloan v. Florida-Vanderbilt Development Corp., 22 Ariz.App. 572 , 529 P.2d 726 (1974).

11980–1980
Klapprott v. United States green
scotus · 1949
2 sentences

1974“In simple English, the language of the ‘other reason’ clause, for all reasons except the five particularly specified, vests power in courts adequate to enable them to vacate judgments whenever such action is appropriate to accomplish justice.” Klapprott v. United States, 335 U.S. 601, 614-615 , 69 S.Ct. 384, 390 , 93 L.Ed. 266 . (emphasis added) The language of part 6 itself indicates that it is a residual clause dealing with matters not covered in the preceding five parts.

1974“In simple English, the language of the ‘other reason’ clause, for all reasons except the five particularly specified, vests power in courts adequate to enable them to vacate judgments whenever such action is appropriate to accomplish justice.” Klapprott v. United States, 335 U.S. 601, 614-615 , 69 S.Ct. 384, 390 , 93 L.Ed. 266 . (emphasis added) The language of part 6 itself indicates that it is a residual clause dealing with matters not covered in the preceding five parts.

11974–1974

Where else courts name it

CT 51 (1988–2025) IL 45 (1984–2026) GA 42 (2008–2026) MN 40 (1970–2026) MT 26 (1988–2017) NC 26 (1984–2023) IA 25 (1994–2024) CA 25 (1982–2026) WI 23 (1978–2025) MI 22 (1998–2023) MA 16 (1982–2024) MS 15 (1968–2017) CO 14 (1986–2026) OR 11 (1984–2026) AZ 11 (1974–2024) NJ 10 (1955–2024) UT 10 (2001–2025) WA 10 (1990–2025) NM 10 (1990–2024) NE 10 (1993–2023) PA 9 (2005–2025) AK 8 (1972–2021) KY 8 (1989–2021) SD 8 (1985–2016) MD 8 (1995–2020) DE 7 (1999–2023) ND 7 (2009–2025) KS 7 (1992–2021) TX 6 (2002–2023) RI 6 (1996–2011) WV 5 (1990–2025) NV 5 (1998–2019) IN 5 (2005–2019) OK 4 (1967–2005) FL 4 (1963–2024) AR 4 (1992–2021) MO 4 (2002–2019) ID 3 (1988–2023) DC 3 (2004–2020) OH 2 (2006–2017) VT 2 (2023–2024) NY 2 (1980–1995) AL 2 (1995–2001) TN 2 (2016–2019) LA 2 (1962–1990) VI 2 (2002–2015) WY 2 (2003–2015)

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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