sense impression exception (Louisiana) · Go Syfert
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sense impression exception in Louisiana

11 Louisiana opinions name it 1 courts 1999–2024 2 in the last five years

The cases below were cited by Louisiana 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 (2)

CaseFollowedCited
Buckbee v. United Gas Pipe Line Co. Inc.green
la · 1990 · cited in 3 Louisiana opinions naming this issue, 2006–2024
2 sentences

2024Furthermore, in determining whether a hearsay statement meets the present sense impression exception, the critical factor is whether the statement was made while the individual was " perceiving" the event or " immediately thereafter." This immediacy requirement permits only the passage of "time needed for translating observation into speech." Buckbee v. United Cas Pipe Line Company, Inc., 561 So.2d 76, 84 ( La. 1990).

2006In State v. Jones, 98-1055 (La.App. 5 Cir. 2/23/99) , 729 So.2d 95, 98 , citing Buckbee v. United Gas Pipe Line Co., Inc., 561 So.2d 76 (La.1990), this Court noted that the Louisiana Supreme Court previously explained a present sense impression exception to the general rule against admitting hearsay, finding, "[t]he statement may follow `immediately' after perceiving an event, allowing only for `the time needed for translating observation into speech.'" Mr. Shipley's statement to Detective Wall did not constitute a present sense impression because it was not made immediately after the event, a

23
State v. Browngreen
lactapp · 1993 · cited in 1 Louisiana opinions naming this issue, 2005–2005
1 sentence

2005See State v. Brown, supra ; State v. Huff, 27, 212 (La.App. 2d Cir.8/23/95), 660 So.2d 529 , writ denied, 96-0212 (La.5/1/97), 693 So.2d 754 . [2] The state urges in brief that the defendant essentially forfeited his right under Crawford to cross-examine Mr. Dabney because he shot and killed Mr. Dabney, effectively and permanently making him unavailable.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
State v. Jones neutral
lactapp · 1999
2 sentences

2014State v. Jones, 98-1055 (La.App. 5 Cir. 2/23/99) , 729 So.2d 95, 98 .

2006In State v. Jones, 98-1055 (La.App. 5 Cir. 2/23/99) , 729 So.2d 95, 98 , citing Buckbee v. United Gas Pipe Line Co., Inc., 561 So.2d 76 (La.1990), this Court noted that the Louisiana Supreme Court previously explained a present sense impression exception to the general rule against admitting hearsay, finding, "[t]he statement may follow `immediately' after perceiving an event, allowing only for `the time needed for translating observation into speech.'" Mr. Shipley's statement to Detective Wall did not constitute a present sense impression because it was not made immediately after the event, a

31999–2014
State v. Francois green
lactapp · 2014
2 sentences

2023App. 5 Cir. 1/31/14), 134 So.3d 42, 56 .

2019“In determining whether a statement qualifies as a present sense impression exception to the hearsay rule, the critical factor is whether the statement was made while the declarant was perceiving the event or immediately thereafter.” State v. Francois, 13-0616, p. 20 (La.App. 5 Cir. 1/31/14), 134 So.3d 42, 56 .

22019–2023
State v. Ditcharo green
la · 2000
2 sentences

2006In State v. Ditcharo, 98-1374 (La.App. 5 Cir. 7/27/99) , 739 So.2d 957, 963 , writ denied, 99-2551 (La.2/18/00), 754 So.2d 964 , this Court found that an officer's testimony was admissible as a present sense impression exception to the general rule against admitting hearsay, as provided for in La.

2000Cf. State v. Ditcharo, 98-1374, p. 10 (La.App. 5 Cir. 7/27/99), 739 So.2d 957, 963 , writ denied, 99-2551 (La.2/18/00), 754 So.2d 964 (where the victim spoke to the police five minutes after she was stabbed and just after she jumped from the defendant's car, officer's testimony about the victim's statements found admissible under the present sense impression exception to the hearsay rule).

22000–2006
State v. Ditcharo green
lactapp · 1999
2 sentences

2006In State v. Ditcharo, 98-1374 (La.App. 5 Cir. 7/27/99) , 739 So.2d 957, 963 , writ denied, 99-2551 (La.2/18/00), 754 So.2d 964 , this Court found that an officer's testimony was admissible as a present sense impression exception to the general rule against admitting hearsay, as provided for in La.

2000Cf. State v. Ditcharo, 98-1374, p. 10 (La.App. 5 Cir. 7/27/99), 739 So.2d 957, 963 , writ denied, 99-2551 (La.2/18/00), 754 So.2d 964 (where the victim spoke to the police five minutes after she was stabbed and just after she jumped from the defendant's car, officer's testimony about the victim's statements found admissible under the present sense impression exception to the hearsay rule).

22000–2006
State v. Heggar green
lactapp · 2005
1 sentence

2014On January 8, 2013, a hearing was conducted on Defendant’s motion in limine, which the trial court denied on March 18, 2013, concluding that the testimony was admissible under the present sense impression exception to the hearsay rule, as set forth in State v. Heggar, 39,915 (La.App. 2 Cir. 8/17/05), 908 So.2d 1245 .

12014–2014
State v. Everett green
lactapp · 2012
1 sentence

2014Id.

12014–2014
State v. Price green
lactapp · 2006
1 sentence

2008Id., 05-2514 at 13, 952 So.2d at 120 .

12008–2008
State v. Parish green
la · 2008
1 sentence

2008Id., 05-2514 at 13, 952 So.2d at 120 .

12008–2008
State v. Huff neutral
la · 1997
1 sentence

2005See State v. Brown, supra ; State v. Huff, 27, 212 (La.App. 2d Cir.8/23/95), 660 So.2d 529 , writ denied, 96-0212 (La.5/1/97), 693 So.2d 754 . [2] The state urges in brief that the defendant essentially forfeited his right under Crawford to cross-examine Mr. Dabney because he shot and killed Mr. Dabney, effectively and permanently making him unavailable.

12005–2005
State v. Huff green
lactapp · 1995
1 sentence

2005See State v. Brown, supra ; State v. Huff, 27, 212 (La.App. 2d Cir.8/23/95), 660 So.2d 529 , writ denied, 96-0212 (La.5/1/97), 693 So.2d 754 . [2] The state urges in brief that the defendant essentially forfeited his right under Crawford to cross-examine Mr. Dabney because he shot and killed Mr. Dabney, effectively and permanently making him unavailable.

12005–2005

Statutes the citing opinions construe

LA § La. Rev. Stat. § 14:2 (3) LA § La. Rev. Stat. § 14:27 (3) LA § La. Rev. Stat. § 14:30.1 (3) LA § La. Rev. Stat. § 14:64 (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

NY 118 (1981–2026) PA 35 (1979–2026) TX 33 (1993–2024) OH 28 (2002–2025) MD 12 (1985–2024) NC 12 (1986–2020) LA 11 (1999–2024) MI 9 (1985–2022) NM 9 (1984–2017) DC 8 (1979–2026) NJ 8 (2008–2022) WV 7 (1987–2026) IN 7 (2008–2020) WY 6 (2003–2025) IL 5 (1997–2016) VA 5 (1987–2010) IA 4 (2018–2022) MO 4 (1991–2015) SC 4 (1998–2019) DE 4 (2001–2021) GA 3 (2018–2022) ND 3 (1995–2017) AZ 3 (1989–2024) NV 2 (2019–2019) AK 2 (2012–2012) UT 2 (2008–2022)

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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