four-pronged test (Florida) · Go Syfert
← Florida issues

four-pronged test in Florida

10 Florida opinions name it 2 courts 1980–2024 2 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 (8)

CaseFollowedCited
Commercial Carrier Corp. v. Indian River Cty.green
fla · 1979 · cited in 2 Florida opinions naming this issue, 1980–1983
2 sentences

1983Commercial Carrier Corp. v. Indian River County, supra, at 1019.

1980See, Commercial Carrier Corp. v. Indian River County, 371 So.2d 1010, 1019 (Fla. 1979).

22
Curtis v. Stategreen
fladistctapp · 2004 · cited in 1 Florida opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., Curtis, 876 So.2d at 21-22 .

2011See, e.g., Curtis, 876 So.2d at 21-22 .

11
Martin v. Stategreen
fla · 1977 · cited in 1 Florida opinions naming this issue, 2008–2008
1 sentence

2008State v. Williams, 198 So.2d 21, 22 (Fla. 1967) (quoting Washington v. State, 86 Fla. 533 , 98 So. 605 , 608 (1923), wherein a declaration emanating two minutes after a shooting was admitted); see also Johnson v. State, 314 So.2d 248, 251 (Fla. 1st DCA 1975) (applying a four-pronged test: the statement must be the natural emanation or outgrowth of the act or occurrence in litigation, made contemporaneously with the act of violence, made voluntarily and spontaneously, and made without any indication of reflection or premeditation); Elmore v. State, 291 So.2d 617, 619 (Fla. 4th DCA 1974) (applyi

11
Johnson v. Stategreen
fladistctapp · 1975 · cited in 1 Florida opinions naming this issue, 2008–2008
1 sentence

2008State v. Williams, 198 So.2d 21, 22 (Fla. 1967) (quoting Washington v. State, 86 Fla. 533 , 98 So. 605 , 608 (1923), wherein a declaration emanating two minutes after a shooting was admitted); see also Johnson v. State, 314 So.2d 248, 251 (Fla. 1st DCA 1975) (applying a four-pronged test: the statement must be the natural emanation or outgrowth of the act or occurrence in litigation, made contemporaneously with the act of violence, made voluntarily and spontaneously, and made without any indication of reflection or premeditation); Elmore v. State, 291 So.2d 617, 619 (Fla. 4th DCA 1974) (applyi

11
Elmore v. Stategreen
fladistctapp · 1974 · cited in 1 Florida opinions naming this issue, 2008–2008
1 sentence

2008State v. Williams, 198 So.2d 21, 22 (Fla. 1967) (quoting Washington v. State, 86 Fla. 533 , 98 So. 605 , 608 (1923), wherein a declaration emanating two minutes after a shooting was admitted); see also Johnson v. State, 314 So.2d 248, 251 (Fla. 1st DCA 1975) (applying a four-pronged test: the statement must be the natural emanation or outgrowth of the act or occurrence in litigation, made contemporaneously with the act of violence, made voluntarily and spontaneously, and made without any indication of reflection or premeditation); Elmore v. State, 291 So.2d 617, 619 (Fla. 4th DCA 1974) (applyi

11
State v. Williamsgreen
fla · 1967 · cited in 1 Florida opinions naming this issue, 2008–2008
1 sentence

2008State v. Williams, 198 So.2d 21, 22 (Fla. 1967) (quoting Washington v. State, 86 Fla. 533 , 98 So. 605 , 608 (1923), wherein a declaration emanating two minutes after a shooting was admitted); see also Johnson v. State, 314 So.2d 248, 251 (Fla. 1st DCA 1975) (applying a four-pronged test: the statement must be the natural emanation or outgrowth of the act or occurrence in litigation, made contemporaneously with the act of violence, made voluntarily and spontaneously, and made without any indication of reflection or premeditation); Elmore v. State, 291 So.2d 617, 619 (Fla. 4th DCA 1974) (applyi

11
King v. City of Seattlegreen
wash · 1974 · cited in 1 Florida opinions naming this issue, 1984–1984
2 sentences

1984Press 1983). [3] The four-pronged test of Evangelical United Brethren Church v. State , commended by Commercial Carrier as a preliminary means of identifying the levels of decision-making activity by governmental agencies, has been further refined by the Washington Supreme Court in King v. City of Seattle, 84 Wash.2d 239 , 525 P.2d 228, 233 (1974), now requiring "the state ... to make a showing that ... [its] policy decision, consciously balancing risks and advantages, took place.

1984Press 1983). [3] The four-pronged test of Evangelical United Brethren Church v. State , commended by Commercial Carrier as a preliminary means of identifying the levels of decision-making activity by governmental agencies, has been further refined by the Washington Supreme Court in King v. City of Seattle, 84 Wash.2d 239 , 525 P.2d 228, 233 (1974), now requiring "the state ... to make a showing that ... [its] policy decision, consciously balancing risks and advantages, took place.

11
Stewart v. Stategreen
wash · 1979 · cited in 1 Florida opinions naming this issue, 1982–1982
2 sentences

1982See Stewart v. State, 92 Wash.2d 285 , 597 P.2d 101, 106-107 (1979). [4] Parenthetically, I would agree with the majority that Section 234.112, authorizing "district school boards to establish school bus stops ... at the most reasonably safe locations available ...", granted to the board the discretion to choose the most reasonably safe location for the stop.

1982See Stewart v. State, 92 Wash.2d 285 , 597 P.2d 101, 106-107 (1979). [4] Parenthetically, I would agree with the majority that Section 234.112, authorizing "district school boards to establish school bus stops ... at the most reasonably safe locations available ...", granted to the board the discretion to choose the most reasonably safe location for the stop.

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 (7)

CaseCitedYears
Kinney System, Inc. v. Continental Ins. Co. green
fla · 1996
2 sentences

2024Id. at 90 (quoting Pain v. United Techs.

2024Id. at 90 (quoting Pain v. United Techs.

22024–2024
Cortez v. Palace Resorts, Inc. green
fla · 2013
2 sentences

2024Cortez v. Palace Resorts, Inc., 123 So. 3d 1085 , 1092–93 (Fla. 2013).

2024Cortez v. Palace Resorts, Inc., 123 So. 3d 1085 , 1092–93 (Fla. 2013).

22024–2024
Washington v. State green
fla · 1923
1 sentence

2008State v. Williams, 198 So.2d 21, 22 (Fla. 1967) (quoting Washington v. State, 86 Fla. 533 , 98 So. 605 , 608 (1923), wherein a declaration emanating two minutes after a shooting was admitted); see also Johnson v. State, 314 So.2d 248, 251 (Fla. 1st DCA 1975) (applying a four-pronged test: the statement must be the natural emanation or outgrowth of the act or occurrence in litigation, made contemporaneously with the act of violence, made voluntarily and spontaneously, and made without any indication of reflection or premeditation); Elmore v. State, 291 So.2d 617, 619 (Fla. 4th DCA 1974) (applyi

12008–2008
Reed v. Cromer green
fla · 1923
1 sentence

2008State v. Williams, 198 So.2d 21, 22 (Fla. 1967) (quoting Washington v. State, 86 Fla. 533 , 98 So. 605 , 608 (1923), wherein a declaration emanating two minutes after a shooting was admitted); see also Johnson v. State, 314 So.2d 248, 251 (Fla. 1st DCA 1975) (applying a four-pronged test: the statement must be the natural emanation or outgrowth of the act or occurrence in litigation, made contemporaneously with the act of violence, made voluntarily and spontaneously, and made without any indication of reflection or premeditation); Elmore v. State, 291 So.2d 617, 619 (Fla. 4th DCA 1974) (applyi

12008–2008
Evangelical United Brethren Church v. State green
wash · 1965
2 sentences

1983Appellees argue, nevertheless, that even absent the Modlin doctrine they are immune from a tort action under the facts alleged by appellants because Deputy Parker's actions came within the discretionary function exception set forth in the four-pronged test of Evangelical United Brethren Church of Adna v. State, 67 Wash.2d 246 , 407 P.2d 440 (1965), as adopted by our supreme court in Commercial Carrier.

1983Appellees argue, nevertheless, that even absent the Modlin doctrine they are immune from a tort action under the facts alleged by appellants because Deputy Parker's actions came within the discretionary function exception set forth in the four-pronged test of Evangelical United Brethren Church of Adna v. State, 67 Wash.2d 246 , 407 P.2d 440 (1965), as adopted by our supreme court in Commercial Carrier.

11983–1983
Johnson v. State of California green
cal · 1968
2 sentences

1983The problem with appellees' position is that while adopting the discretionary function test of Evangelical, our supreme court also adopted the "planning" versus "operational" test of Johnson v. State, 69 Cal.2d 782 , 73 Cal. Rptr. 240 , 447 P.2d 352 (1968).

1983The problem with appellees' position is that while adopting the discretionary function test of Evangelical, our supreme court also adopted the "planning" versus "operational" test of Johnson v. State, 69 Cal.2d 782 , 73 Cal. Rptr. 240 , 447 P.2d 352 (1968).

11983–1983
Knight v. State green
fla · 1981
1 sentence

1981In Knight v. State, 394 So.2d 997 (Fla. 1981), this Court set out a four-pronged test for determining whether there was reasonably effective assistance: *909 1.

11981–1981

Statutes the citing opinions construe

FL § 768.28 (4)

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

PA 72 (1974–2026) NJ 31 (1987–2026) CT 29 (1983–2026) MI 28 (1981–2021) TX 17 (1981–2025) GA 17 (1981–2026) WA 13 (2004–2026) IL 13 (1974–2006) NY 11 (1974–2024) FL 10 (1980–2024) OH 10 (1987–2026) AL 8 (1991–2015) ID 8 (1995–2022) RI 8 (1979–2016) VA 7 (1987–2012) NC 6 (1976–2018) CA 6 (1995–2014) MO 6 (1976–2001) WV 5 (1996–2023) UT 4 (1984–2001) TN 4 (1979–2010) LA 4 (2008–2023) MN 4 (1981–2015) DC 3 (1978–1996) KY 3 (2015–2024) WI 2 (1986–2003) VT 2 (1984–1989) MS 2 (2012–2014) IN 2 (1998–2006) ND 2 (2022–2022) KS 2 (1985–1990) MA 2 (2014–2022) WY 2 (1989–2003) NM 2 (2014–2014)

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.

← Caselaw search · G Cite Topics · Brief Check