Roberts reliability analysis (Florida) · Go Syfert
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Roberts reliability analysis in Florida

9 Florida opinions name it 2 courts 2005–2025 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
Crawford v. Washingtongreen
scotus · 2004 · cited in 7 Florida opinions naming this issue, 2007–2025
2 sentences

2025In Crawford, Justice Scalia authored the Court’s majority opinion, which overruled Roberts and held that “[w]here 7 testimonial statements are at issue, the only indicium of reliability sufficient to satisfy constitutional demands is the one the Constitution actually prescribes: confrontation.” Crawford, 541 U.S. at 68-69; see also Blanton v. State, 978 So. 2d 149, 154 (Fla. 2008) (“In Crawford, the Supreme Court dispensed with the Roberts reliability analysis for testimonial hearsay statements[.]”).

2016As the Florida Supreme Court has noted, although the United- States Supreme Court "receded from the Roberts reliability test in Crawford [v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed,2d 177 (2004) ],” it cited "Roberts with approval for the proposition that prior trial or hearing testimony is admissible only if the defendant had an adequate opportunity to cross-examine.

37
State v. Contrerasgreen
fla · 2008 · cited in 2 Florida opinions naming this issue, 2016–2024
2 sentences

2024But, regardless, the effect of overturning Roberts was that the Confrontation Clause analysis was restored to its original common law understanding, except in the factual circumstances applicable in Craig—where “a State’s interest in the physical and psychological well-being of child abuse victims may be sufficiently important to outweigh, at least in some cases, a defendant’s right to face his or her accusers in court.” Craig, 497 U.S. at 853 ; see also State v. Contreras, 979 So. 2d 896, 902 (Fla. 2008) (recognizing that “[i]n Crawford, the Supreme Court dispensed with the Roberts reliabilit

2016The Supreme Court noted that the testimony from a preliminary hearing was properly admitted in Roberts because the defendant had examined the witness at that hearing.” Contreras, 979 So.2d at 909 n. 5 (citation omitted).

12
Blanton v. Stategreen
fla · 2008 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025In Crawford, Justice Scalia authored the Court’s majority opinion, which overruled Roberts and held that “[w]here 7 testimonial statements are at issue, the only indicium of reliability sufficient to satisfy constitutional demands is the one the Constitution actually prescribes: confrontation.” Crawford, 541 U.S. at 68-69; see also Blanton v. State, 978 So. 2d 149, 154 (Fla. 2008) (“In Crawford, the Supreme Court dispensed with the Roberts reliability analysis for testimonial hearsay statements[.]”).

11
Billy Jo Faughn v. Commonwealth of Kentuckygreen
ky · 2024 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024But, regardless, the effect of overturning Roberts was that the Confrontation Clause analysis was restored to its original common law understanding, except in the factual circumstances applicable in Craig—where “a State’s interest in the physical and psychological well-being of child abuse victims may be sufficiently important to outweigh, at least in some cases, a defendant’s right to face his or her accusers in court.” Craig, 497 U.S. at 853 ; see also State v. Contreras, 979 So. 2d 896, 902 (Fla. 2008) (recognizing that “[i]n Crawford, the Supreme Court dispensed with the Roberts reliabilit

11
Franqui v. Stategreen
fla · 1997 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Abreu, 837 So.2d 400, 402 (Fla.2003); Farina v. State, 679 So.2d 1151, 1157 (Fla. 1996), receded from by Franqui v. State, 699 So.2d 1312, 1320 (Fla.1997); Perez v. State, 536 So.2d 206, 209 (Fla.1988); Glendening v. State, 536 So.2d 212, 217 (Fla. 1988).

11
State v. Abreugreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Abreu, 837 So.2d 400, 402 (Fla.2003); Farina v. State, 679 So.2d 1151, 1157 (Fla. 1996), receded from by Franqui v. State, 699 So.2d 1312, 1320 (Fla.1997); Perez v. State, 536 So.2d 206, 209 (Fla.1988); Glendening v. State, 536 So.2d 212, 217 (Fla. 1988).

11
Glendening v. Stategreen
fla · 1988 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Abreu, 837 So.2d 400, 402 (Fla.2003); Farina v. State, 679 So.2d 1151, 1157 (Fla. 1996), receded from by Franqui v. State, 699 So.2d 1312, 1320 (Fla.1997); Perez v. State, 536 So.2d 206, 209 (Fla.1988); Glendening v. State, 536 So.2d 212, 217 (Fla. 1988).

11
Perez v. Stategreen
fla · 1988 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Abreu, 837 So.2d 400, 402 (Fla.2003); Farina v. State, 679 So.2d 1151, 1157 (Fla. 1996), receded from by Franqui v. State, 699 So.2d 1312, 1320 (Fla.1997); Perez v. State, 536 So.2d 206, 209 (Fla.1988); Glendening v. State, 536 So.2d 212, 217 (Fla. 1988).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Farina v. Stateyellow
fla · 1996 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Abreu, 837 So.2d 400, 402 (Fla.2003); Farina v. State, 679 So.2d 1151, 1157 (Fla. 1996), receded from by Franqui v. State, 699 So.2d 1312, 1320 (Fla.1997); Perez v. State, 536 So.2d 206, 209 (Fla.1988); Glendening v. State, 536 So.2d 212, 217 (Fla. 1988).

11

Also cited on this issue (2)

CaseCitedYears
Maryland v. Craig green
scotus · 1990
1 sentence

2024But, regardless, the effect of overturning Roberts was that the Confrontation Clause analysis was restored to its original common law understanding, except in the factual circumstances applicable in Craig—where “a State’s interest in the physical and psychological well-being of child abuse victims may be sufficiently important to outweigh, at least in some cases, a defendant’s right to face his or her accusers in court.” Craig, 497 U.S. at 853 ; see also State v. Contreras, 979 So. 2d 896, 902 (Fla. 2008) (recognizing that “[i]n Crawford, the Supreme Court dispensed with the Roberts reliabilit

12024–2024
Frye v. United States red
cadc · 1923
1 sentence

2008See Crawford, 541 U.S. at 58 , 124 S.Ct. 1354 . [3] Category A witnesses include: eyewitnesses; alibi witnesses and rebuttal to alibi witnesses; witnesses present when a recorded or unrecorded statement was made by a defendant or codefendant; investigating officers; witnesses known by the prosecutor to have exculpatory material information; child hearsay witnesses; and expert witnesses who have not provided a written' report and curriculum vitae or who are going to testify as to test results or give opinions subject to Frye v. United States, 293 F. 1013 (D.C.Cir.1923).

12008–2008

Statutes the citing opinions construe

FL § 90.803 (5) FL § 90.801 (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

FL 9 (2005–2025) TX 5 (2005–2006) CA 3 (2005–2008) MS 2 (2006–2008) MN 2 (2004–2005) MA 2 (2004–2005) CO 2 (2004–2005) OH 2 (2004–2005)

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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