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11 Virginia opinions name it 2 courts 1999–2018 0 in the last five years
The cases below were cited by Virginia 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 |
|---|---|---|
Crawford v. Washingtongreen2 sentences2018In Crawford v. Washington, 541 U.S. 36, 51-52 (2004), the United States Supreme Court abandoned the Roberts test and classified certain specific types of evidence as “testimonial.” Under Crawford, when evidence is testimonial, it cannot be introduced at trial without a testifying witness unless that witness is unavailable and the defendant previously had an opportunity to cross-examine the witness on that evidence. 2018In Crawford v. Washington, 541 U.S. 36, 51-52 (2004), the United States Supreme Court abandoned the Roberts test and classified certain specific types of evidence as “testimonial.” Under Crawford, when evidence is testimonial, it cannot be introduced at trial without a testifying witness unless that witness is unavailable and the defendant previously had an opportunity to cross-examine the witness on that evidence. | 2 | 8 |
Southern Railway Co. v. Minorgreen2 sentences2010Co. v. Minor, 196 Ga.App. 183 , 395 S.E.2d 845, 847 (1990) (evaluating under state law whether a trial court erred in striking a juror for cause in a FELA action); Auer v. Burlington N. R.R. 2010Co. v. Minor, 196 Ga.App. 183 , 395 S.E.2d 845, 847 (1990) (evaluating under state law whether a trial court erred in striking a juror for cause in a FELA action); Auer v. Burlington N. R.R. | 1 | 1 |
Hodges v. Com.green2 sentences2008In Crawford , the Supreme Court rejected the Roberts analysis and held that "[w]here testimonial evidence is at issue, ... the Sixth Amendment demands what the common law required: unavailability [of the witness] and a prior opportunity for cross-examination." 541 U.S. at 68 , 124 S.Ct. 1354 ; accord Hodges v. Commonwealth, 272 Va. 418 , 428-29, 634 S.E.2d 680 , 685 (2006). 2008In Crawford , the Supreme Court rejected the Roberts analysis and held that "[w]here testimonial evidence is at issue, ... the Sixth Amendment demands what the common law required: unavailability [of the witness] and a prior opportunity for cross-examination." 541 U.S. at 68 , 124 S.Ct. 1354 ; accord Hodges v. Commonwealth, 272 Va. 418 , 428-29, 634 S.E.2d 680 , 685 (2006). | 1 | 1 |
State v. Manuelgreen2 sentences2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 | 1 | 1 |
De La Garza v. Stringfellowgreen2 sentences2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 | 1 | 1 |
Worley v. United States Court of Appeals for the Fourth Circuitgreen2 sentences2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 | 1 | 1 |
Horton v. Allengreen2 sentences2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 | 1 | 1 |
State v. Statengreen2 sentences2005State v. Staten, 364 S.C. 7 , 610 S.E.2d 823, 836 (Ct.App.2005) (alterations in original). 2005State v. Staten, 364 S.C. 7 , 610 S.E.2d 823, 836 (Ct.App.2005) (alterations in original). | 1 | 1 |
United States v. James Saget, Also Known as Heshgreen2 sentences2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Prophet v. BULLOCK CORP.
green
1 sentence2013Appellants contend the commission erred in: (1) refusing to reconsider its review opinion; (2) applying Prophet v. Bullock Corp., 59 Va. App. 313 , 718 S.E.2d 478 (2011), rather than following prior decisions from the Court of Appeals; and (3) failing to recognize Prophet was wrongly decided. | 1 | 2013–2013 |
State v. Uhde
neutral
2 sentences2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 2005Most jurisdictions are leaning toward the idea that " Crawford [left] the Roberts approach untouched with respect to nontestimonial statements." United States v. Saget, 377 F.3d 223, 227 (2d Cir.2004); see also Horton v. Allen, 370 F.3d 75, 84 (1st Cir.2004) ("Thus, unless [witness's hearsay] statements qualify as `testimonial,' Crawford is inapplicable and Roberts continues to apply.") [, cert. denied, ___ U.S. ___, 125 S.Ct. 971 , 160 L.Ed.2d 905 (2005)]; State v. Manuel, 275 Wis.2d 146 , 2004 WI App 111 , 685 N.W.2d 525, 533 (Wis.Ct.App.2004), review granted, 2004 WI 138 , 276 Wis.2d 26 , 6 | 1 | 2005–2005 |
Ohio v. Roberts
red
2 sentences1999In this case, there is no "showing of particularized guarantees of trustworthiness," id., that would make the codefendant's statement admissible against Pitt under the second prong of the Roberts test. 1999In this case, there is no "showing of particularized guarantees of trustworthiness," id., that would make the codefendant's statement admissible against Pitt under the second prong of the Roberts test. | 1 | 1999–1999 |
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.