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12 Florida opinions name it 2 courts 1967–2025 1 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.
| Case | Followed | Cited |
|---|---|---|
State v. Madoriegreen2 sentences2019Crosby , 110 Ohio App. At 229, 162 N.E.2d at 130 (citing 6 American State Trials, page 73 (1819) Vermont); see also *1047 State v. Madorie , 156 S.W.3d 351 , 354 (Mo. 2005) ("By the end of the 19th century, almost every jurisdiction in the United States adopted some form of a corroboration requirement for all crimes."). 2019Crosby , 110 Ohio App. At 229, 162 N.E.2d at 130 (citing 6 American State Trials, page 73 (1819) Vermont); see also *1047 State v. Madorie , 156 S.W.3d 351 , 354 (Mo. 2005) ("By the end of the 19th century, almost every jurisdiction in the United States adopted some form of a corroboration requirement for all crimes."). | 2 | 2 |
United States v. Raul Lopez-Alvarezgreen1 sentence2005In United States v. Lopez-Alvarez, 970 F.2d 583, 592 (9th Cir.1992), the Ninth Circuit concluded that the corroboration requirement of Opper is two-pronged: [F]irst, although the state need not introduce independent evidence of the corpus delicti in conformance with the traditional test, it must introduce sufficient evidence to establish that the criminal conduct at the core of the offense has occurred. | 1 | 1 |
State v. Townsendgreen1 sentence1999Thus, in State v. Townsend, 635 So.2d 949, 957 (Fla.1994), the court said that "the other corroborating evidence requirement [in section 90.803(23)(a)2b] assures that a defendant will not be convicted solely on the basis of the hearsay testimony." It would seem that permitting one or more of the alleged child-victim's out-of-court statements to be used to satisfy the corroboration requirement of section 90.803(23)(a)2b would permit a defendant to "be convicted solely on the basis of the hearsay testimony." Moreover, in Jones v. State, 728 So.2d 788 , 24 Fla. L. | 1 | 1 |
State v. Parkergreen2 sentences1993State v. Parker, 315 N.C. 222 , 337 S.E.2d 487, 493 (1985) (underscoring deleted; citations omitted). 1993State v. Parker, 315 N.C. 222 , 337 S.E.2d 487, 493 (1985) (underscoring deleted; citations omitted). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Sciortino v. State
green
2 sentences2019Nonetheless, in its learned decision rendered in Sciortino v. State , 115 So.2d 93 , 99 (Fla. 2d DCA 1959), the Second District Court of Appeal set forth the following principles with regard to evidentiary sufficiency in cases involving extrajudicial confessions: 1. 2019Nonetheless, in its learned decision rendered in Sciortino v. State , 115 So.2d 93 , 99 (Fla. 2d DCA 1959), the Second District Court of Appeal set forth the following principles with regard to evidentiary sufficiency in cases involving extrajudicial confessions: 1. | 2 | 2019–2019 |
State v. Cosby
green
2 sentences2019Crosby , 110 Ohio App. At 229, 162 N.E.2d at 130 (citing 6 American State Trials, page 73 (1819) Vermont); see also *1047 State v. Madorie , 156 S.W.3d 351 , 354 (Mo. 2005) ("By the end of the 19th century, almost every jurisdiction in the United States adopted some form of a corroboration requirement for all crimes."). 2019Crosby , 110 Ohio App. At 229, 162 N.E.2d at 130 (citing 6 American State Trials, page 73 (1819) Vermont); see also *1047 State v. Madorie , 156 S.W.3d 351 , 354 (Mo. 2005) ("By the end of the 19th century, almost every jurisdiction in the United States adopted some form of a corroboration requirement for all crimes."). | 2 | 2019–2019 |
Jones v. State
green
2 sentences2000In Jones v. State, 728 So.2d 788 (Fla. 1st DCA 1999), the First District held that the other corroborative evidence need not even stem from the charged crime. 1999Thus, in State v. Townsend, 635 So.2d 949, 957 (Fla.1994), the court said that "the other corroborating evidence requirement [in section 90.803(23)(a)2b] assures that a defendant will not be convicted solely on the basis of the hearsay testimony." It would seem that permitting one or more of the alleged child-victim's out-of-court statements to be used to satisfy the corroboration requirement of section 90.803(23)(a)2b would permit a defendant to "be convicted solely on the basis of the hearsay testimony." Moreover, in Jones v. State, 728 So.2d 788 , 24 Fla. L. | 2 | 1999–2000 |
STATE OF FLORIDA v. MARCUS NATHAN JACKSON
neutral
1 sentence2025Cf. State v. Jackson, 385 So. 3d 189 , 192 (Fla. 2d DCA 2024) (Atkinson, J., dissenting) ("Section 92.565 differentiates between the 'memorialized confession or admission' that is the subject of the trustworthiness requirement and 'the defendant's statements' that may be used as 'corroborating evidence' to prove the trustworthiness of the memorialized confession or admission the State seeks to admit into evidence."). | 1 | 2025–2025 |
Ghelichkhani v. State
green
1 sentence2001The "common thread" of the case law construing the corroboration requirement of section 90.803(23) is the corroborative evidence "tends to confirm the unlawful sexual act, i.e., the `abuse or offense.'" Id. | 1 | 2001–2001 |
Doyle v. State
green
2 sentences1981Since Florida courts could not create a corroboration requirement as Georgia courts had in Davis v. State, 120 Ga. 433 , 48 S.E. 180 (1904), because of such precedent as Doyle v. State, 39 Fla. 155 , 22 So. 272 (1897), they instead sought to create a separate category of appellate review based on evidentiary weight, implementing a de facto corroboration requirement. 1981Since Florida courts could not create a corroboration requirement as Georgia courts had in Davis v. State, 120 Ga. 433 , 48 S.E. 180 (1904), because of such precedent as Doyle v. State, 39 Fla. 155 , 22 So. 272 (1897), they instead sought to create a separate category of appellate review based on evidentiary weight, implementing a de facto corroboration requirement. | 1 | 1981–1981 |
Davis v. State
green
2 sentences1981Since Florida courts could not create a corroboration requirement as Georgia courts had in Davis v. State, 120 Ga. 433 , 48 S.E. 180 (1904), because of such precedent as Doyle v. State, 39 Fla. 155 , 22 So. 272 (1897), they instead sought to create a separate category of appellate review based on evidentiary weight, implementing a de facto corroboration requirement. 1981Since Florida courts could not create a corroboration requirement as Georgia courts had in Davis v. State, 120 Ga. 433 , 48 S.E. 180 (1904), because of such precedent as Doyle v. State, 39 Fla. 155 , 22 So. 272 (1897), they instead sought to create a separate category of appellate review based on evidentiary weight, implementing a de facto corroboration requirement. | 1 | 1981–1981 |
Crouch v. Crouch
green
2 sentences1970See the cases collected in the annotation in 57 A.L.R.2d 942 et seq.; 27 Am.Jur., Husband and Wife, Sec. 275, p. 881, and Sec. 326, p. 923; Werlein v. Werlein, 1965, 27 Wis.2d 237 , 133 N.W.2d 820 ; Crouch v. Crouch, 1964, 53 Tenn. App. 594 , 385 S.W.2d 288 ; Motley v. Motley, 1961, 255 N.C. 190 , 120 S.E.2d 422 . 1970See the cases collected in the annotation in 57 A.L.R.2d 942 et seq.; 27 Am.Jur., Husband and Wife, Sec. 275, p. 881, and Sec. 326, p. 923; Werlein v. Werlein, 1965, 27 Wis.2d 237 , 133 N.W.2d 820 ; Crouch v. Crouch, 1964, 53 Tenn. App. 594 , 385 S.W.2d 288 ; Motley v. Motley, 1961, 255 N.C. 190 , 120 S.E.2d 422 . | 1 | 1970–1970 |
Motley v. Motley
green
2 sentences1970See the cases collected in the annotation in 57 A.L.R.2d 942 et seq.; 27 Am.Jur., Husband and Wife, Sec. 275, p. 881, and Sec. 326, p. 923; Werlein v. Werlein, 1965, 27 Wis.2d 237 , 133 N.W.2d 820 ; Crouch v. Crouch, 1964, 53 Tenn. App. 594 , 385 S.W.2d 288 ; Motley v. Motley, 1961, 255 N.C. 190 , 120 S.E.2d 422 . 1970See the cases collected in the annotation in 57 A.L.R.2d 942 et seq.; 27 Am.Jur., Husband and Wife, Sec. 275, p. 881, and Sec. 326, p. 923; Werlein v. Werlein, 1965, 27 Wis.2d 237 , 133 N.W.2d 820 ; Crouch v. Crouch, 1964, 53 Tenn. App. 594 , 385 S.W.2d 288 ; Motley v. Motley, 1961, 255 N.C. 190 , 120 S.E.2d 422 . | 1 | 1970–1970 |
Werlein v. Werlein
green
2 sentences1970See the cases collected in the annotation in 57 A.L.R.2d 942 et seq.; 27 Am.Jur., Husband and Wife, Sec. 275, p. 881, and Sec. 326, p. 923; Werlein v. Werlein, 1965, 27 Wis.2d 237 , 133 N.W.2d 820 ; Crouch v. Crouch, 1964, 53 Tenn. App. 594 , 385 S.W.2d 288 ; Motley v. Motley, 1961, 255 N.C. 190 , 120 S.E.2d 422 . 1970See the cases collected in the annotation in 57 A.L.R.2d 942 et seq.; 27 Am.Jur., Husband and Wife, Sec. 275, p. 881, and Sec. 326, p. 923; Werlein v. Werlein, 1965, 27 Wis.2d 237 , 133 N.W.2d 820 ; Crouch v. Crouch, 1964, 53 Tenn. App. 594 , 385 S.W.2d 288 ; Motley v. Motley, 1961, 255 N.C. 190 , 120 S.E.2d 422 . | 1 | 1970–1970 |
Clutter v. Clutter
neutral
1 sentence1968Morgan v. Morgan, Fla.1949, 40 So.2d 778 ; Clutter v. Clutter, Fla.App. 1968, 207 So.2d 499 ; Martin v. Martin, Fla. App.1958, 102 So.2d 837 ; 3 Nelson, Divorce and Annulment § 26.13; 3 U.Fla.L.Rev. 125 (1950). | 1 | 1968–1968 |
Morgan v. Morgan
neutral
1 sentence1968Morgan v. Morgan, Fla.1949, 40 So.2d 778 ; Clutter v. Clutter, Fla.App. 1968, 207 So.2d 499 ; Martin v. Martin, Fla. App.1958, 102 So.2d 837 ; 3 Nelson, Divorce and Annulment § 26.13; 3 U.Fla.L.Rev. 125 (1950). | 1 | 1968–1968 |
Martin v. Martin
green
1 sentence1968Morgan v. Morgan, Fla.1949, 40 So.2d 778 ; Clutter v. Clutter, Fla.App. 1968, 207 So.2d 499 ; Martin v. Martin, Fla. App.1958, 102 So.2d 837 ; 3 Nelson, Divorce and Annulment § 26.13; 3 U.Fla.L.Rev. 125 (1950). | 1 | 1968–1968 |
Gantling v. State
green
1 sentence1967Referring to a similarly worded instruction, the Florida Supreme Court, in Gantling v. State, 1898, 40 Fla. 237, 247 , 23 So. 857 , 860, noted: "* * * The instruction under consideration was calculated to impress the jury with the idea that the law would not permit them to discard the entire testimony of such a witness, where he was corroborated by some circumstance or another credible witness in the case; and it was, therefore, erroneous." For this reason the decision in Gantling was reversed, establishing as the law of this state that it is erroneous to include corroboration clauses in "fals | 1 | 1967–1967 |
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.
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.