second step inquiry (District of Columbia) · Go Syfert
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second step inquiry in District of Columbia

11 District of Columbia opinions name it 1 courts 1984–2026 4 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 (10)

CaseFollowedCited
Ali Baba Co., Inc. v. Wilco, Inc.green
dc · 1984 · cited in 2 District of Columbia opinions naming this issue, 2006–2013
2 sentences

2013“To guard against unfairness in [the] ... context [of non-mutual offensive collateral estoppel], the trial court adds a second step to its inquiry and considers the fairness of applying collateral estoppel to the facts of the case.” Id. (citing Ali Baba, supra, 482 A.2d at 423 ).

2006See Ali Baba Co., 482 A.2d at 423 .

12
Sweet v. United Statesgreen
dc · 1982 · cited in 1 District of Columbia opinions naming this issue, 2026–2026
1 sentence

2026To be sure, this testimony risked enormous prejudice to Phillips, as it posed a genuine risk that the jury would “infer improperly that [he] committed the charged offense[s] because he had committed other crimes in the past.” Sweet v. United 14 States, 449 A.2d 315, 319 (D.C. 1982); Jenkins v. United States, 80 A.3d 978, 999 (D.C. 2013) (“Evidence of an uncharged murder undeniably has a prejudicial impact.”).

11
Emanuel Jenkins and Azariah Israel v. United Statesgreen
dc · 2013 · cited in 1 District of Columbia opinions naming this issue, 2026–2026
1 sentence

2026To be sure, this testimony risked enormous prejudice to Phillips, as it posed a genuine risk that the jury would “infer improperly that [he] committed the charged offense[s] because he had committed other crimes in the past.” Sweet v. United 14 States, 449 A.2d 315, 319 (D.C. 1982); Jenkins v. United States, 80 A.3d 978, 999 (D.C. 2013) (“Evidence of an uncharged murder undeniably has a prejudicial impact.”).

11
Hernandez v. New Yorkgreen
scotus · 1991 · cited in 1 District of Columbia opinions naming this issue, 2023–2023
1 sentence

2023Unless a discriminatory intent is inherent in the prosecutor’s explanation, the reason offered will be deemed race neutral.” Purkett 11 v. Elem, 514 U.S. 765, 767-68 (1995) (brackets omitted) (quoting Hernandez v. New York, 500 U.S. 352, 360 (1991) (plurality opinion)).

11
Purkett v. Elemgreen
scotus · 1995 · cited in 1 District of Columbia opinions naming this issue, 2023–2023
1 sentence

2023Unless a discriminatory intent is inherent in the prosecutor’s explanation, the reason offered will be deemed race neutral.” Purkett 11 v. Elem, 514 U.S. 765, 767-68 (1995) (brackets omitted) (quoting Hernandez v. New York, 500 U.S. 352, 360 (1991) (plurality opinion)).

11
Gaines v. Dist. of Columbia Dep't of Emp't Servs.green
dc · 2019 · cited in 1 District of Columbia opinions naming this issue, 2022–2022
1 sentence

2022At the second step of the analysis, which we likewise reached in Gaines after concluding the risk was “at a minimum neutral,” we concluded that Gaines’s injury would not have occurred “but for the fact that her job required her to go to the Farragut North station in order to work a shift there.” Id. at 772, 773 .

11
Odemns v. United Statesgreen
dc · 2006 · cited in 1 District of Columbia opinions naming this issue, 2017–2017
1 sentence

2017Odemns v. United States, 901 A.2d 770, 776 (D.C. 2006) (explaining that the statement must be made “within a reasonably short period of time after the [shocking incident] so as to assure that the declarant has not reflected upon his statement or premeditated or constructed it”).

11
Noonan v. Williamsgreen
dc · 1996 · cited in 1 District of Columbia opinions naming this issue, 2011–2011
1 sentence

2011See id. at 244-245 .

11
Yelverton v. United Statesgreen
dc · 2006 · cited in 1 District of Columbia opinions naming this issue, 2011–2011
1 sentence

2011While “[t]he decision on what further instructions, if any, to give in response to a jury question lies within the sound discretion of the trial court[,] ... [w]hen a jury makes explicit its difficulties, a trial judge should clear them away with concrete accuracy.” Yelverton v. United States, 904 A.2d 383, 387 (D.C.2006) (internal quotations and citations omitted).

11
Oregon v. Bradshawgreen
scotus · 1983 · cited in 1 District of Columbia opinions naming this issue, 1984–1984
1 sentence

1984The second step of the analysis requires the government to prove a valid waiver of the previously asserted right to have counsel present during interrogation. 12 Bradshaw, supra, 103 S.Ct. at 2834-35.

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 (5)

CaseCitedYears
Logan v. District of Columbia Department of Employment Services green
dc · 2002
1 sentence

2021In Logan, however, this court 9 described the second step of the test more broadly, as whether the employer had provided “sufficient evidence of suitable job availability to overcome a finding of total disability.” 805 A.2d at 243 .

12021–2021
Washington v. United States green
dc · 2005
1 sentence

2016In reviewing allegations of prosecutorial misconduct at trial, we begin by determining whether the challenged conduct actually was improper.15 If it was not, 15 See, e.g., Washington v. United States, 884 A.2d 1080 , 1088 (D.C. 2005). 12 that ends our inquiry, and we have no occasion to go on to evaluate the trial court’s response and whether there was reversible error.16 In the present case, we do not reach the second step in the analysis, because we reject appellant’s claims of impropriety.

12016–2016
Davis v. Davis green
dc · 1995
1 sentence

2013“To guard against unfairness in [the] ... context [of non-mutual offensive collateral estoppel], the trial court adds a second step to its inquiry and considers the fairness of applying collateral estoppel to the facts of the case.” Id. (citing Ali Baba, supra, 482 A.2d at 423 ).

12013–2013
Parklane Hosiery Co. v. Shore green
scotus · 1979
2 sentences

2013The Supreme Court’s opinion in Parklane Hosiery Co., Inc. v. Shore, 439 U.S. 322 , 99 S.Ct. 645 , 58 L.Ed.2d 552 (1979), sets forth the rationale for the offensive use of non-mutual collateral estoppel, and explains the Court’s conclusion that “the preferable approach for dealing with these problems [that attend its use] in the federal courts is not to preclude the use of offensive collateral estoppel, but to grant trial courts broad discretion to determine when it should be applied.” Id. at 331 , 99 S.Ct. 645 (footnote omitted).

2013The Supreme Court’s opinion in Parklane Hosiery Co., Inc. v. Shore, 439 U.S. 322 , 99 S.Ct. 645 , 58 L.Ed.2d 552 (1979), sets forth the rationale for the offensive use of non-mutual collateral estoppel, and explains the Court’s conclusion that “the preferable approach for dealing with these problems [that attend its use] in the federal courts is not to preclude the use of offensive collateral estoppel, but to grant trial courts broad discretion to determine when it should be applied.” Id. at 331 , 99 S.Ct. 645 (footnote omitted).

12013–2013
Edwards v. Arizona green
scotus · 1981
2 sentences

1984The Court in Edwards stated: If, as frequently would occur in the course of a meeting initiated by the accused, the conversation is not wholly one-sided, it is likely that the officers will say or do something that clearly would be “interrogation.” In that event, the question would be whether a valid waiver of the right to counsel and the right to silence had occurred, that is, whether the purported waiver was knowing and intelligent and found to be so under the totality of the circumstances, including the necessary fact that the accused, not the police, reopened the dialogue with the authorit

1984The Court in Edwards stated: If, as frequently would occur in the course of a meeting initiated by the accused, the conversation is not wholly one-sided, it is likely that the officers will say or do something that clearly would be “interrogation.” In that event, the question would be whether a valid waiver of the right to counsel and the right to silence had occurred, that is, whether the purported waiver was knowing and intelligent and found to be so under the totality of the circumstances, including the necessary fact that the accused, not the police, reopened the dialogue with the authorit

11984–1984

Where else courts name it

TX 253 (1984–2026) CA 185 (1964–2026) OH 96 (1984–2025) IL 95 (1984–2026) IN 76 (1989–2025) IA 58 (1988–2026) MO 53 (1988–2019) OR 44 (1985–2026) KS 43 (1994–2026) WI 34 (1988–2026) NM 33 (1993–2026) WA 31 (1995–2025) PA 25 (1981–2026) NJ 24 (1983–2026) GA 23 (1985–2026) TN 23 (2001–2020) RI 21 (1983–2021) MI 20 (1975–2026) CT 20 (1985–2023) ID 20 (1993–2026) MN 18 (1988–2026) NY 17 (1988–2025) NC 15 (1986–2022) LA 14 (1991–2017) FL 14 (1999–2021) CO 14 (1989–2025) NV 11 (2012–2024) DE 11 (1983–2026) KY 11 (2010–2025) DC 11 (1984–2026) ME 11 (1981–2025) SC 10 (1990–2017) MD 9 (1993–2025) NE 9 (2015–2019) MS 9 (2007–2024) UT 9 (1991–2026) VT 8 (1990–2025) NH 8 (1985–2021) AR 7 (2018–2025) MA 7 (1981–2024) WY 7 (2005–2025) AK 5 (2019–2025) WV 5 (1989–2017) SD 4 (1985–2018) ND 4 (2002–2016) MT 4 (2003–2025) AL 4 (1994–2016) VI 4 (2012–2024) VA 4 (1992–2025) HI 3 (2002–2015) OK 2 (1991–2011)

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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