excited utterance hearsay exception (Washington) · Go Syfert
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excited utterance hearsay exception in Washington

11 Washington opinions name it 2 courts 1997–2023 1 in the last five years

The cases below were cited by Washington 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 (3)

CaseFollowedCited
State v. Woodsgreen
wash · 2001 · cited in 5 Washington opinions naming this issue, 2004–2016
2 sentences

2016App. 611, 614 , 128 P.3d 631 (2006); but see State v. Woods, 143 Wn. d 561, 595, 23 P.3d 1046 (2001) (applying an abuse of discretion standard of review t the excited utterance hearsay exception, which requires application of evidentiary facto s by the trial court).

2016But see State v. Woods, 143 Wn.2d 561, 595 , 23 P.3d 1046 (2001) (applying an abuse of discretion standard of review to the excited utterance hearsay exception, which requires application of evidentiary factors by the trial court).

15
State v. Woodsgreen
wash · 2001 · cited in 4 Washington opinions naming this issue, 2004–2016
2 sentences

2016But see State v. Woods, 143 Wn.2d 561, 595 , 23 P.3d 1046 (2001) (applying an abuse of discretion standard of review to the excited utterance hearsay exception, which requires application of evidentiary factors by the trial court).

2009See Woods, 143 Wash.2d at 599-601 , 23 P.3d 1046 (statements made 45 minutes after assailant left the crime scene were properly admitted); see also State v. Flett, 40 Wash.App. 277, 287 , 699 P.2d 774 (1985) (statements made seven hours after rape deemed properly admitted upon finding *497 of "continuing stress" between time of rape and statement). ¶ 67 The three requirements of the excited utterance hearsay exception are satisfied.

14
State v. Flettgreen
washctapp · 1985 · cited in 2 Washington opinions naming this issue, 2009–2009
2 sentences

2009App. 277, 287 , 699 P.2d 774 (1985) (statements made seven hours after rape deemed properly admitted upon finding of “continuing stress” between time of rape and statement). ¶67 The three requirements of the excited utterance hearsay exception are satisfied.

2009See Woods, 143 Wash.2d at 599-601 , 23 P.3d 1046 (statements made 45 minutes after assailant left the crime scene were properly admitted); see also State v. Flett, 40 Wash.App. 277, 287 , 699 P.2d 774 (1985) (statements made seven hours after rape deemed properly admitted upon finding *497 of "continuing stress" between time of rape and statement). ¶ 67 The three requirements of the excited utterance hearsay exception are satisfied.

12

Distinguished, questioned or overruled (2)

CaseNegativeCited
State v. Woodsgreen
wash · 2001 · cited in 5 Washington opinions naming this issue, 2004–2016
2 sentences

2016App. 611, 614 , 128 P.3d 631 (2006); but see State v. Woods, 143 Wn. d 561, 595, 23 P.3d 1046 (2001) (applying an abuse of discretion standard of review t the excited utterance hearsay exception, which requires application of evidentiary facto s by the trial court).

2016But see State v. Woods, 143 Wn.2d 561, 595 , 23 P.3d 1046 (2001) (applying an abuse of discretion standard of review to the excited utterance hearsay exception, which requires application of evidentiary factors by the trial court).

25
State v. Woodsgreen
wash · 2001 · cited in 4 Washington opinions naming this issue, 2004–2016
2 sentences

2016But see State v. Woods, 143 Wn.2d 561, 595 , 23 P.3d 1046 (2001) (applying an abuse of discretion standard of review to the excited utterance hearsay exception, which requires application of evidentiary factors by the trial court).

2009See Woods, 143 Wash.2d at 599-601 , 23 P.3d 1046 (statements made 45 minutes after assailant left the crime scene were properly admitted); see also State v. Flett, 40 Wash.App. 277, 287 , 699 P.2d 774 (1985) (statements made seven hours after rape deemed properly admitted upon finding *497 of "continuing stress" between time of rape and statement). ¶ 67 The three requirements of the excited utterance hearsay exception are satisfied.

14

Also cited on this issue (5)

CaseCitedYears
State v. Chapin green
wash · 1992
2 sentences

1997State v. Chapin, 118 Wn.2d 681, 686 , 826 P.2d 194 (1992) (citing 6 John Henry Wigmore, Evidence § 1747, at 195 (James H.

1997State v. Chapin, 118 Wn.2d 681, 686 , 826 P.2d 194 (1992) (citing 6 John Henry Wigmore, Evidence § 1747, at 195 (James H.

21997–1997
State v. Rodriquez green
washctapp · 2015
1 sentence

2023State v. Rodriquez, 187 Wn.

12023–2023
State v. Edwards green
washctapp · 2006
1 sentence

2016App. 611, 614 , 128 P.3d 631 (2006); but see State v. Woods, 143 Wn. d 561, 595, 23 P.3d 1046 (2001) (applying an abuse of discretion standard of review t the excited utterance hearsay exception, which requires application of evidentiary facto s by the trial court).

12016–2016
State v. Lui green
wash · 2014
1 sentence

2014Id. at 469 .

12014–2014
Shipley v. United States green
scotus · 2014
1 sentence

2014Id.

12014–2014

Where else courts name it

TX 51 (2001–2025) OH 13 (2006–2025) WA 11 (1997–2023) PA 7 (2009–2023) FL 6 (1994–2019) TN 6 (1999–2021) NC 4 (1988–2024) CA 4 (1978–2015) WI 3 (1993–2021) MI 3 (1989–2026) AZ 2 (1993–2015) SC 2 (2005–2025) NJ 2 (2005–2018) LA 2 (1989–1995) NY 2 (1998–2010) KS 2 (2002–2020) IL 2 (2007–2025)

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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