Roberts test (Minnesota) · Go Syfert
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Roberts test in Minnesota

10 Minnesota opinions name it 2 courts 1986–2008 0 in the last five years

The cases below were cited by Minnesota 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 (4)

CaseFollowedCited
Crawford v. Washingtongreen
scotus · 2004 · cited in 6 Minnesota opinions naming this issue, 2004–2006
2 sentences

2006In Crawford , the Supreme Court rejected the Roberts test, explaining that “the principal evil at which the Confrontation Clause was directed was the civil-law mode of criminal procedure, and particularly its use of ex parte examinations as evidence against the accused.” Crawford, 541 U.S. at 50 , 124 S.Ct. 1354 .

2006In Crawford , the Supreme Court rejected the Roberts test, explaining that “the principal evil at which the Confrontation Clause was directed was the civil-law mode of criminal procedure, and particularly its use of ex parte examinations as evidence against the accused.” Crawford, 541 U.S. at 50 , 124 S.Ct. 1354 .

36
State v. Martingreen
minn · 2005 · cited in 2 Minnesota opinions naming this issue, 2006–2008
2 sentences

2008In State v. Martin, decided before Davis , we indicated that nontestimonial statements had to meet the Roberts test to be admitted consistent with the Confrontation Clause. 695 N.W.2d 578, 584 (Minn.2005).

2008In State v. Martin, decided before Davis , we indicated that nontestimonial statements had to meet the Roberts test to be admitted consistent with the Confrontation Clause. 695 N.W.2d 578, 584 (Minn.2005).

22
Idaho v. Wrightgreen
scotus · 1990 · cited in 1 Minnesota opinions naming this issue, 1991–1991
2 sentences

1991See id.

1991See id.

11
Becker v. Commissioner of Public Safetygreen
minnctapp · 1985 · cited in 1 Minnesota opinions naming this issue, 1986–1986
2 sentences

1986See Becker v. Commissioner of Public Safety, 374 N.W.2d 303 (Minn.Ct.App.1985).

1986See Becker v. Commissioner of Public Safety, 374 N.W.2d 303 (Minn.Ct.App.1985).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Ohio v. Roberts red
scotus · 1980
2 sentences

2004The Roberts test allowed a jury to hear hearsay evidence if (1) the declarant was unavailable to testify, and (2) the statement bore “indicia of reliability.” Id.

2004The Roberts test allowed a jury to hear hearsay evidence if (1) the declarant was unavailable to testify, and (2) the statement bore “indicia of reliability.” Id.

22004–2006
United States v. Inadi, Joseph. Appeal of Joseph Inadi green
ca3 · 1985
2 sentences

1991In Inadi, 748 F.2d 812 (3d Cir.1984), rev’d, 475 U.S. 387 , 106 S.Ct. 1121 , 89 L.Ed.2d 390 (1986), the Third Circuit concluded that there was no reason to deviate from the unavailability requirement where the government sought to introduce hearsay statements of a non-testifying coconspirator.

1991In Inadi, 748 F.2d 812 (3d Cir.1984), rev’d, 475 U.S. 387 , 106 S.Ct. 1121 , 89 L.Ed.2d 390 (1986), the Third Circuit concluded that there was no reason to deviate from the unavailability requirement where the government sought to introduce hearsay statements of a non-testifying coconspirator.

11991–1991
United States v. Inadi green
scotus · 1986
2 sentences

1991However, I firmly disagree with the majority’s suggestion that United States v. Inadi, 475 U.S. 387 , 106 S.Ct. 1121 , 89 L.Ed.2d 390 (1986), worked any substantial change in the Roberts rule.

1991However, I firmly disagree with the majority’s suggestion that United States v. Inadi, 475 U.S. 387 , 106 S.Ct. 1121 , 89 L.Ed.2d 390 (1986), worked any substantial change in the Roberts rule.

11991–1991

Statutes the citing opinions construe

MN § Minn. Stat. § 609.342 (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

TX 40 (1976–2022) CA 38 (1953–2026) GA 29 (1984–2026) WA 29 (1978–2015) FL 28 (1972–2025) OH 24 (1992–2025) CO 18 (1965–2025) IL 18 (1987–2024) PA 17 (1977–2024) OR 17 (1989–2025) NY 14 (1993–2025) NC 13 (1876–2017) ID 12 (1991–2021) KS 12 (1989–2022) HI 11 (1995–2022) VA 11 (1999–2018) MN 10 (1986–2008) MD 9 (1987–2014) MS 9 (1987–2022) WI 9 (1989–2019) UT 8 (2002–2021) CT 8 (1990–2018) AL 8 (1987–2026) NJ 7 (1988–2008) MO 7 (1983–2017) TN 7 (2006–2013) NM 6 (1993–2007) IA 6 (1978–2024) WY 6 (1976–2013) SC 6 (2000–2014) AR 6 (2005–2016) NH 6 (2000–2017) MT 5 (1996–2025) MA 5 (1972–2004) MI 5 (1991–2019) IN 5 (2004–2019) KY 5 (2011–2024) ME 4 (1987–2014) DC 4 (1984–2014) AZ 4 (1986–2006) OK 3 (2002–2004) LA 2 (1989–2008) NV 2 (1998–2018) RI 2 (2010–2013)

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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