residual exception (New Mexico) · Go Syfert
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residual exception in New Mexico

10 New Mexico opinions name it 2 courts 1990–2024 1 in the last five years

The cases below were cited by New Mexico 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 (7)

CaseFollowedCited
Idaho v. Wrightgreen
scotus · 1990 · cited in 3 New Mexico opinions naming this issue, 1992–2000
2 sentences

2000We do not believe that we have interpreted the residual exception in a way which can be considered a broadening of that exception with commensurate concern that the exception might eventually “swallow the entirety of the hearsay rule.” Id., 61 F.3d at 1452 .

1999See Ross, 122 N.M. at 23 , 919 P.2d at 1088 . {16} “[Statements offered under the residual exception are considered ‘presumptively unreliable and inadmissible under the Confrontation Clause’ unless they possess sufficient guarantees of trustworthiness to permit their admission into evidence.” 5 Weinstein & Berger, supra, § 807.03[2][c] at 807-18.1-18-2 (quoting Wright, 497 U.S. at 818 , 110 S.Ct. 3139 ).

13
State v. Freedgreen
nmctapp · 1996 · cited in 1 New Mexico opinions naming this issue, 2024–2024
1 sentence

2024See In re Ernesto M., Jr., 1996-NMCA-039 , ¶ 10, 121 N.M. 562 , 915 P.2d 318 (“An assertion of prejudice is not a showing of prejudice.”). {4} In Defendant’s memorandum in opposition, he states that the judge did not rule on the hearsay objection, and the letter could have come in under the residual exception to the hearsay rule.

11
Matter of Ernesto M., Jr.green
nmctapp · 1996 · cited in 1 New Mexico opinions naming this issue, 2024–2024
1 sentence

2024See In re Ernesto M., Jr., 1996-NMCA-039 , ¶ 10, 121 N.M. 562 , 915 P.2d 318 (“An assertion of prejudice is not a showing of prejudice.”). {4} In Defendant’s memorandum in opposition, he states that the judge did not rule on the hearsay objection, and the letter could have come in under the residual exception to the hearsay rule.

11
Woolwine v. Furr's, Inc.green
nmctapp · 1987 · cited in 1 New Mexico opinions naming this issue, 2019–2019
2 sentences

2019See Woolwine v. Furr’s, Inc., 1987-NMCA-133 , ¶ 20, 106 N.M. 492 , 745 P.2d 717 (“To preserve an issue for review on appeal, it must appear that appellant fairly invoked a ruling of the trial court on the same grounds argued in the appellate court.”).

2019See Woolwine v. Furr’s, Inc., 1987-NMCA-133 , ¶ 20, 106 N.M. 492 , 745 P.2d 717 (“To preserve an issue for review on appeal, it must appear that appellant fairly invoked a ruling of the trial court on the same grounds argued in the appellate court.”).

11
Corona v. Coronagreen
nmctapp · 2014 · cited in 1 New Mexico opinions naming this issue, 2019–2019
1 sentence

2019See Corona v. Corona, 12 1 2014-NMCA-071, ¶ 28 , 329 P.3d 701 (stating that we will not “review an 2 argument that is not adequately developed”); Muse v. Muse, 2009-NMCA-003 , ¶ 3 72, 145 N.M. 451 , 200 P.3d 104 (“We will not search the record for facts, 4 arguments, and rulings in order to support generalized arguments.”).

11
State ex rel. Children, Youth & Families Department v. Pamela R.D.G.green
nm · 2006 · cited in 1 New Mexico opinions naming this issue, 2016–2016
1 sentence

2016Rule 11-807(A)(3) 8 NMRA; see In re Pamela A.G., 2006-NMSC-019, ¶¶ 1-7 ; State v. Doe, 1980-NMCA- 9 091, ¶ 7. 10 {7} Defendant cites State v. Whitfield, No. 29,774 mem. op.

11
State v. Rossgreen
nm · 1996 · cited in 1 New Mexico opinions naming this issue, 1999–1999
2 sentences

1999See Ross, 122 N.M. at 23 , 919 P.2d at 1088 . {16} “[Statements offered under the residual exception are considered ‘presumptively unreliable and inadmissible under the Confrontation Clause’ unless they possess sufficient guarantees of trustworthiness to permit their admission into evidence.” 5 Weinstein & Berger, supra, § 807.03[2][c] at 807-18.1-18-2 (quoting Wright, 497 U.S. at 818 , 110 S.Ct. 3139 ).

1999See Ross, 122 N.M. at 23 , 919 P.2d at 1088 . {16} “[Statements offered under the residual exception are considered ‘presumptively unreliable and inadmissible under the Confrontation Clause’ unless they possess sufficient guarantees of trustworthiness to permit their admission into evidence.” 5 Weinstein & Berger, supra, § 807.03[2][c] at 807-18.1-18-2 (quoting Wright, 497 U.S. at 818 , 110 S.Ct. 3139 ).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
City of Santa Fe v. Komis green
nm · 1992
2 sentences

2019See Rule 11-703 NMRA; City of Santa Fe v. Komis, 1992-NMSC-051 , 16 ¶ 25 n.4, 114 N.M. 659 , 845 P.2d 753 (“While experts may rely on hearsay under 17 Rule [11-]703, the hearsay itself is not admissible.”). 18 {22} To the extent Cutliff relies on Rule 11-807, the residual exception to the 19 hearsay rule, he does not explain why the medical records should have been 20 admitted under this rule, and we decline to consider it.

2019See Rule 11-703 NMRA; City of Santa Fe v. Komis, 1992-NMSC-051 , 16 ¶ 25 n.4, 114 N.M. 659 , 845 P.2d 753 (“While experts may rely on hearsay under 17 Rule [11-]703, the hearsay itself is not admissible.”). 18 {22} To the extent Cutliff relies on Rule 11-807, the residual exception to the 19 hearsay rule, he does not explain why the medical records should have been 20 admitted under this rule, and we decline to consider it.

22019–2019
State v. Taylor green
nmctapp · 1985
2 sentences

2013The statements described or explained both the event and the victim’s condition, as Navarro had directly perceived them. {21} In response, Defendant cites State v. Taylor, 1985-NMCA-063 , ¶¶ 35-49, 103 N.M. 189 , 704 P.2d 443 , in which the court assessed the reliability and trustworthiness of hearsay statements admitted under the residual exception to the hearsay rule.

2013The statements described or explained both the event and the victim’s condition, as Navarro had directly perceived them. {21} In response, Defendant cites State v. Taylor, 1985-NMCA-063 , ¶¶ 35-49, 103 N.M. 189 , 704 P.2d 443 , in which the court assessed the reliability and trustworthiness of hearsay statements admitted under the residual exception to the hearsay rule.

22013–2013
Muse v. Muse green
nmctapp · 2008
2 sentences

2019See Corona v. Corona, 12 1 2014-NMCA-071, ¶ 28 , 329 P.3d 701 (stating that we will not “review an 2 argument that is not adequately developed”); Muse v. Muse, 2009-NMCA-003 , ¶ 3 72, 145 N.M. 451 , 200 P.3d 104 (“We will not search the record for facts, 4 arguments, and rulings in order to support generalized arguments.”).

2019See Corona v. Corona, 12 1 2014-NMCA-071, ¶ 28 , 329 P.3d 701 (stating that we will not “review an 2 argument that is not adequately developed”); Muse v. Muse, 2009-NMCA-003 , ¶ 3 72, 145 N.M. 451 , 200 P.3d 104 (“We will not search the record for facts, 4 arguments, and rulings in order to support generalized arguments.”).

12019–2019
United States v. Matthew Wayne Tome green
ca10 · 1995
1 sentence

2000We do not believe that we have interpreted the residual exception in a way which can be considered a broadening of that exception with commensurate concern that the exception might eventually “swallow the entirety of the hearsay rule.” Id., 61 F.3d at 1452 .

12000–2000
State v. Barela green
nmctapp · 1982
2 sentences

1992State v. Barela, 97 N.M. 723 , 643 P.2d 287 (Ct.App. 1982).

1992State v. Barela, 97 N.M. 723 , 643 P.2d 287 (Ct.App. 1982).

11992–1992
Lee v. Illinois green
scotus · 1986
2 sentences

1992Since statements under the residual hearsay clause "do not share the same tradition of reliability that supports the admissibility of statements under a firmly rooted hearsay exception," such statements are "`presumptively unreliable and inadmissible for Confrontation Clause purposes.'" Wright, 497 U.S. at ___ , 110 S.Ct. at 3148 , 111 L.Ed.2d at 653 -54 (quoting Lee v. Illinois, 476 U.S. 530, 543 , 106 S.Ct. 2056, 2063 , 90 L.Ed.2d 514 (1986)).

1992Since statements under the residual hearsay clause "do not share the same tradition of reliability that supports the admissibility of statements under a firmly rooted hearsay exception," such statements are "`presumptively unreliable and inadmissible for Confrontation Clause purposes.'" Wright, 497 U.S. at ___ , 110 S.Ct. at 3148 , 111 L.Ed.2d at 653 -54 (quoting Lee v. Illinois, 476 U.S. 530, 543 , 106 S.Ct. 2056, 2063 , 90 L.Ed.2d 514 (1986)).

11992–1992
Foundation Reserve Insurance v. Martin green
nmctapp · 1968
2 sentences

1990Co. v. Martin, 79 N.M. 737 , 449 P.2d 339 (Ct.App.1968).

1990Co. v. Martin, 79 N.M. 737 , 449 P.2d 339 (Ct.App.1968).

11990–1990

Statutes the citing opinions construe

NM § N.M. Stat. § 30-2-1 (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

CT 51 (1988–2025) IL 45 (1984–2026) GA 42 (2008–2026) MN 40 (1970–2026) MT 26 (1988–2017) NC 26 (1984–2023) IA 25 (1994–2024) CA 25 (1982–2026) WI 23 (1978–2025) MI 22 (1998–2023) MA 16 (1982–2024) MS 15 (1968–2017) CO 14 (1986–2026) OR 11 (1984–2026) AZ 11 (1974–2024) NJ 10 (1955–2024) UT 10 (2001–2025) WA 10 (1990–2025) NM 10 (1990–2024) NE 10 (1993–2023) PA 9 (2005–2025) AK 8 (1972–2021) KY 8 (1989–2021) SD 8 (1985–2016) MD 8 (1995–2020) DE 7 (1999–2023) ND 7 (2009–2025) KS 7 (1992–2021) TX 6 (2002–2023) RI 6 (1996–2011) WV 5 (1990–2025) NV 5 (1998–2019) IN 5 (2005–2019) OK 4 (1967–2005) FL 4 (1963–2024) AR 4 (1992–2021) MO 4 (2002–2019) ID 3 (1988–2023) DC 3 (2004–2020) OH 2 (2006–2017) VT 2 (2023–2024) NY 2 (1980–1995) AL 2 (1995–2001) TN 2 (2016–2019) LA 2 (1962–1990) VI 2 (2002–2015) WY 2 (2003–2015)

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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