automatic standing rule (Florida) · Go Syfert
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automatic standing rule in Florida

11 Florida opinions name it 2 courts 1980–2006 0 in the last five years

The cases below were cited by Florida 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
Jones v. United Statesred
scotus · 1960 · cited in 7 Florida opinions naming this issue, 1980–1988
2 sentences

1988In Salvucci , the United States Supreme Court rejected the automatic standing rule of Jones v. United States, 362 U.S. 257 , 80 S.Ct. 725 , 4 L.Ed.2d 697 (1960), cert. dismissed, 368 U.S. 801 , 82 S.Ct. 20 , 7 L.Ed.2d 15 (1961). [2] Instead, the Court held that "we must instead engage in a `conscientious effort to apply the Fourth Amendment' by asking not merely whether the defendant had a possessory interest in the items seized, but whether he had an expectation of privacy in the area searched." 448 U.S. at 93 , 100 S.Ct. at 2553 , 65 L.Ed.2d at 629 .

1988In Salvucci , the United States Supreme Court rejected the automatic standing rule of Jones v. United States, 362 U.S. 257 , 80 S.Ct. 725 , 4 L.Ed.2d 697 (1960), cert. dismissed, 368 U.S. 801 , 82 S.Ct. 20 , 7 L.Ed.2d 15 (1961). [2] Instead, the Court held that "we must instead engage in a `conscientious effort to apply the Fourth Amendment' by asking not merely whether the defendant had a possessory interest in the items seized, but whether he had an expectation of privacy in the area searched." 448 U.S. at 93 , 100 S.Ct. at 2553 , 65 L.Ed.2d at 629 .

17
State v. Loefflergreen
fladistctapp · 1982 · cited in 1 Florida opinions naming this issue, 2006–2006
1 sentence

2006In State v. Hutchinson, 404 So.2d 361 (Fla. 2d DCA 1981), and State v. Loeffler, 410 So.2d 589, 591 (Fla. 2d DCA 1982), this court found that Salvucci was controlling and rejected the automatic standing rule.

11
Shafi v. Stategreen
fladistctapp · 1979 · cited in 1 Florida opinions naming this issue, 1980–1980
1 sentence

1980See also Lego v. Twomey, 404 U.S. 477 , 92 S.Ct. 619 , 30 L.Ed.2d 618 (1972). [5] In Shafi v. State, 377 So.2d 787 (Fla. 1st DCA 1979), the court cites Jones as having expanded the scope of standing, but does not mention that Shafi's standing derives from the automatic standing rule.

11
Lego v. Twomeygreen
scotus · 1972 · cited in 1 Florida opinions naming this issue, 1980–1980
2 sentences

1980See also Lego v. Twomey, 404 U.S. 477 , 92 S.Ct. 619 , 30 L.Ed.2d 618 (1972). [5] In Shafi v. State, 377 So.2d 787 (Fla. 1st DCA 1979), the court cites Jones as having expanded the scope of standing, but does not mention that Shafi's standing derives from the automatic standing rule.

1980See also Lego v. Twomey, 404 U.S. 477 , 92 S.Ct. 619 , 30 L.Ed.2d 618 (1972). [5] In Shafi v. State, 377 So.2d 787 (Fla. 1st DCA 1979), the court cites Jones as having expanded the scope of standing, but does not mention that Shafi's standing derives from the automatic standing rule.

11
Rakas v. Illinoisgreen
scotus · 1979 · cited in 1 Florida opinions naming this issue, 1980–1980
2 sentences

1980See Rakas v. Illinois, supra, 439 U.S. [128] at 135 n. 4, 99 S.Ct. 421 [at 426 n. 4, 58 L.Ed.2d 387 ]; Brown v. United States, supra, 411 U.S. [223] at 228, 229, 93 S.Ct. 1565 [at 1568, 1569, 36 L.Ed.2d 208 ], Since the Supreme Court first questioned the vitality of this doctrine in Brown , there has been a split of authority as to whether the doctrine survives.

1980See Rakas v. Illinois, supra, 439 U.S. [128] at 135 n. 4, 99 S.Ct. 421 [at 426 n. 4, 58 L.Ed.2d 387 ]; Brown v. United States, supra, 411 U.S. [223] at 228, 229, 93 S.Ct. 1565 [at 1568, 1569, 36 L.Ed.2d 208 ], Since the Supreme Court first questioned the vitality of this doctrine in Brown , there has been a split of authority as to whether the doctrine survives.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (9)

CaseCitedYears
United States v. Salvucci green
scotus · 1980
2 sentences

2006Washington noted that the United States Supreme Court had abandoned the automatic standing rule in United States v. Salvucci, 448 U.S. 83 , 100 S.Ct. 2547 , 65 L.Ed.2d 619 (1980), but the Washington Supreme Court had repeatedly affirmed the rule's validity.

2006Washington noted that the United States Supreme Court had abandoned the automatic standing rule in United States v. Salvucci, 448 U.S. 83 , 100 S.Ct. 2547 , 65 L.Ed.2d 619 (1980), but the Washington Supreme Court had repeatedly affirmed the rule's validity.

71981–2006
Norman v. State green
fladistctapp · 1980
2 sentences

1981We accept the reasoning of our sister court in Norman v. State, 388 So.2d 613 (Fla. 3d DCA 1980) that the automatic standing rule has not become a part of this state’s law in order to survive the overruling of Jones v. United States, 362 U.S. 257 , 80 S.Ct. 725 , 4 L.Ed.2d 697 (1960) by the United States Supreme Court in United States v. Salvucci, 448 U.S. 83 , 100 S.Ct. 2547 , 65 L.Ed.2d 619 (1980) and Rawlings v. Kentucky, 448 U.S. 98 , 100 S.Ct. 2556 , 65 L.Ed.2d 633 (1980).

1981The automatic standing rule has been abolished by both the United States Supreme Court in U. S. v. Salvucci, 448 U.S. 83 , 100 S.Ct. 2547 , 65 L.Ed.2d 619 (1980) and in Florida in Norman v. State, 388 So.2d 613 (Fla. 3d DCA 1980).

31981–1981
United States v. John M. Salvucci, Jr., Joseph G. Zackular green
ca1 · 1979
2 sentences

1981Relying upon Jones v. United States, 362 U.S. 257 , 80 S.Ct. 725 , 4 L.Ed.2d 697 (1960), and United States v. Salvucci, 599 F.2d 1094 (1st Cir. 1979), holding that the automatic standing rule announced in Jones was still the law, the district court held that the defendants in this case had automatic standing to challenge the legality of the searches and seizures, and it reversed the trial court’s findings in this regard.

1980In United States v. Salvucci, 599 F.2d 1094 (1st Cir. 1979), the court held that the following automatic standing rule, extrapolated from Jones , is still the law: [A] defendant [charged with an offense] has automatic standing to challenge the legality of a search or seizure if charged with a crime that includes, as an essential element of the offense charged, possession of the seized evidence at the time of the contested search and seizure. 559 F.2d at 1097.

21980–1981
State v. Hutchinson green
fladistctapp · 1981
1 sentence

2006In State v. Hutchinson, 404 So.2d 361 (Fla. 2d DCA 1981), and State v. Loeffler, 410 So.2d 589, 591 (Fla. 2d DCA 1982), this court found that Salvucci was controlling and rejected the automatic standing rule.

12006–2006
Antipas v. United States green
scotus · 1961
1 sentence

1988In Salvucci , the United States Supreme Court rejected the automatic standing rule of Jones v. United States, 362 U.S. 257 , 80 S.Ct. 725 , 4 L.Ed.2d 697 (1960), cert. dismissed, 368 U.S. 801 , 82 S.Ct. 20 , 7 L.Ed.2d 15 (1961). [2] Instead, the Court held that "we must instead engage in a `conscientious effort to apply the Fourth Amendment' by asking not merely whether the defendant had a possessory interest in the items seized, but whether he had an expectation of privacy in the area searched." 448 U.S. at 93 , 100 S.Ct. at 2553 , 65 L.Ed.2d at 629 .

11988–1988
King v. State green
fladistctapp · 1978
1 sentence

1982E.g., King v. State, 371 So.2d 120 (Fla. 1st DCA 1978), cert. denied, 378 So.2d 349 (Fla.1979).

11982–1982
Rawlings v. Kentucky green
scotus · 1980
2 sentences

1981We accept the reasoning of our sister court in Norman v. State, 388 So.2d 613 (Fla. 3d DCA 1980) that the automatic standing rule has not become a part of this state’s law in order to survive the overruling of Jones v. United States, 362 U.S. 257 , 80 S.Ct. 725 , 4 L.Ed.2d 697 (1960) by the United States Supreme Court in United States v. Salvucci, 448 U.S. 83 , 100 S.Ct. 2547 , 65 L.Ed.2d 619 (1980) and Rawlings v. Kentucky, 448 U.S. 98 , 100 S.Ct. 2556 , 65 L.Ed.2d 633 (1980).

1981We accept the reasoning of our sister court in Norman v. State, 388 So.2d 613 (Fla. 3d DCA 1980) that the automatic standing rule has not become a part of this state’s law in order to survive the overruling of Jones v. United States, 362 U.S. 257 , 80 S.Ct. 725 , 4 L.Ed.2d 697 (1960) by the United States Supreme Court in United States v. Salvucci, 448 U.S. 83 , 100 S.Ct. 2547 , 65 L.Ed.2d 619 (1980) and Rawlings v. Kentucky, 448 U.S. 98 , 100 S.Ct. 2556 , 65 L.Ed.2d 633 (1980).

11981–1981
Mapp v. Ohio green
scotus · 1961
2 sentences

1980Our course would be clear had the exclusionary rule laid down in Mapp v. Ohio, 367 U.S. 643 , 81 S.Ct. 1684 , 6 L.Ed.2d 1081 (1961), been the victim of Salvucci .

1980Our course would be clear had the exclusionary rule laid down in Mapp v. Ohio, 367 U.S. 643 , 81 S.Ct. 1684 , 6 L.Ed.2d 1081 (1961), been the victim of Salvucci .

11980–1980
Brown v. United States green
scotus · 1973
2 sentences

1980See Rakas v. Illinois, supra, 439 U.S. [128] at 135 n. 4, 99 S.Ct. 421 [at 426 n. 4, 58 L.Ed.2d 387 ]; Brown v. United States, supra, 411 U.S. [223] at 228, 229, 93 S.Ct. 1565 [at 1568, 1569, 36 L.Ed.2d 208 ], Since the Supreme Court first questioned the vitality of this doctrine in Brown , there has been a split of authority as to whether the doctrine survives.

1980See Rakas v. Illinois, supra, 439 U.S. [128] at 135 n. 4, 99 S.Ct. 421 [at 426 n. 4, 58 L.Ed.2d 387 ]; Brown v. United States, supra, 411 U.S. [223] at 228, 229, 93 S.Ct. 1565 [at 1568, 1569, 36 L.Ed.2d 208 ], Since the Supreme Court first questioned the vitality of this doctrine in Brown , there has been a split of authority as to whether the doctrine survives.

11980–1980

Where else courts name it

WA 35 (1980–2019) NY 28 (1972–2015) MA 25 (1988–2021) NJ 17 (2001–2024) FL 11 (1980–2006) IL 11 (1980–1995) PA 9 (1989–2024) CT 7 (1996–2008) AL 7 (1980–1983) WI 5 (1981–2007) MS 5 (1982–2023) MI 5 (1981–1986) ND 5 (1980–1993) NH 5 (1982–1999) MT 4 (1979–2018) HI 3 (2002–2007) VT 3 (1991–2011) MN 3 (1982–1999) OH 3 (1995–2025) CA 3 (1985–1990) TX 2 (1975–2004) TN 2 (1982–1982) IN 2 (1981–1989) IA 2 (1979–2015) KY 2 (1979–1980) MD 2 (1976–1981) OR 2 (1980–1981) RI 2 (1980–1981) CO 2 (1980–1985)

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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