spousal privilege (Indiana) · Go Syfert
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spousal privilege in Indiana

9 Indiana opinions name it 2 courts 1978–2016 0 in the last five years

The cases below were cited by Indiana 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
Carlyle v. Stategreen
ind · 1981 · cited in 2 Indiana opinions naming this issue, 2001–2003
2 sentences

2003However, the marital privilege is not absolute. "[Wlhere a spouse's testimony concerns disclosures by the other spouse not made in reliance upon the marital relationship but because the disclosing spouse was in need of his mate's assistance and attempted to coerce by force and fear, the testimony is not within the spousal privilege and is admissible." Id.; see also Carlyle v. State, 428 N.E.2d 10, 12 (Ind.1981).

2001Carlyle v. State, 428 N.E.2d 10, 12 (Ind.1981); see Rode, 524 N.E.2d at 800 .

22
Russell v. Stategreen
ind · 2001 · cited in 2 Indiana opinions naming this issue, 2003–2016
2 sentences

2016See, e.g., Russell v. State, 743 N.E.2d 269 (Ind.2001) (holding that the admission of the defendant’s wife’s testimony in violation of the spousal privilege was harmless error).

2003Also not privileged are "[clommunications *1156 between spouses intended to be transmitted to a third person." Russell, 743 N.E.2d at 272 (citing Perkins v. State, 483 N.E.2d 1379, 1383 (Ind.1985)).

12
Holt v. Stategreen
ind · 1985 · cited in 2 Indiana opinions naming this issue, 2004–2007
2 sentences

2007Holt v. State, 481 N.E.2d 1324, 1326 (Ind.1985).

2007Holt v. State, 481 N.E.2d 1324, 1326 (Ind.1985).

12
Baggett v. Stategreen
ind · 1987 · cited in 1 Indiana opinions naming this issue, 2014–2014
1 sentence

2014And the testimony of Windhorn’s wife could either have been voluntary through her own waiver of the spousal privilege, see Glover v. State, 836 N.E.2d 414 (Ind. 2005) (noting that Indiana’s spousal privilege “does not bar the spouse from testifying if the spouse chooses to do so”), or the court could have compelled Windhorn’s wife to testify under our child protection laws, see Baggett v. State, 514 N.E.2d 1244, 1245 (Ind. 1987) (“the privileged communication between a husband and wife is not a ground for excluding evidence in any judicial proceeding resulting from a report of a child who may

11
State v. Chrismoregreen
iowa · 1937 · cited in 1 Indiana opinions naming this issue, 2004–2004
2 sentences

2004State v. Chrismore, 223 Iowa 957 , 274 N.W. 3, 5 (1937) (holding that [when the marriage ceremony is performed, no matter what the motive was or may be, the witness thenceforward becomes the lawful wife of defendant, and is prohibited under our statute from testifying against her husband, except where the offense is by the husband against her person.") Additionally, we believe accepting the State's position would allow for the creation of numerous "exceptions" to the spousal privilege and create undue uncertainty in its application if courts were to routinely inquire into the "quality" of a ma

2004State v. Chrismore, 223 Iowa 957 , 274 N.W. 3, 5 (1937) (holding that [when the marriage ceremony is performed, no matter what the motive was or may be, the witness thenceforward becomes the lawful wife of defendant, and is prohibited under our statute from testifying against her husband, except where the offense is by the husband against her person.") Additionally, we believe accepting the State's position would allow for the creation of numerous "exceptions" to the spousal privilege and create undue uncertainty in its application if courts were to routinely inquire into the "quality" of a ma

11
Taylor v. Stategreen
ind · 1991 · cited in 1 Indiana opinions naming this issue, 2004–2004
1 sentence

2004The spousal privilege is subject to waiver where the defendant gives direct testimony concerning his communication with his spouse during the time in question, Taylor v. State, 567 N.E.2d 98, 102 (Ind.1991).

11
Perkins v. Stategreen
ind · 1985 · cited in 1 Indiana opinions naming this issue, 2003–2003
1 sentence

2003Also not privileged are "[clommunications *1156 between spouses intended to be transmitted to a third person." Russell, 743 N.E.2d at 272 (citing Perkins v. State, 483 N.E.2d 1379, 1383 (Ind.1985)).

11
Rode v. Stategreen
indctapp · 1988 · cited in 1 Indiana opinions naming this issue, 2001–2001
1 sentence

2001Carlyle v. State, 428 N.E.2d 10, 12 (Ind.1981); see Rode, 524 N.E.2d at 800 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Stevens v. State green
ind · 1976
2 sentences

1978In Stevens v. State, (1976) 265 Ind. 396 , 354 N.E.2d 727 , we held that notwithstanding frequent broad statements in the opinions of this Court that the defense of insanity opens the doors to otherwise inadmissible evidence, the assertion of such defense did not render admissible a communication excludable under the spousal privilege.

1978In Stevens v. State, (1976) 265 Ind. 396 , 354 N.E.2d 727 , we held that notwithstanding frequent broad statements in the opinions of this Court that the defense of insanity opens the doors to otherwise inadmissible evidence, the assertion of such defense did not render admissible a communication excludable under the spousal privilege.

21978–1978
Glover v. State green
ind · 2005
1 sentence

2014And the testimony of Windhorn’s wife could either have been voluntary through her own waiver of the spousal privilege, see Glover v. State, 836 N.E.2d 414 (Ind. 2005) (noting that Indiana’s spousal privilege “does not bar the spouse from testifying if the spouse chooses to do so”), or the court could have compelled Windhorn’s wife to testify under our child protection laws, see Baggett v. State, 514 N.E.2d 1244, 1245 (Ind. 1987) (“the privileged communication between a husband and wife is not a ground for excluding evidence in any judicial proceeding resulting from a report of a child who may

12014–2014
Shepherd v. State green
ind · 1971
2 sentences

2004Shepherd, 257 Ind. at 232-33 , 277 N.E.2d at 167 .

2004Shepherd, 257 Ind. at 232-33 , 277 N.E.2d at 167 .

12004–2004
Beyerline v. State green
ind · 1897
2 sentences

2004Beyerline, 147 Ind. at 130 , 45 N.E. at 774 .

2004Beyerline, 147 Ind. at 130 , 45 N.E. at 774 .

12004–2004
State v. Farber green
indctapp · 1997
1 sentence

1998State v. Farber, 677 N.E.2d 1111 (Ind.Ct.App.1997), trans. denied.

11998–1998

Statutes the citing opinions construe

IN § Ind. Code § 35-50-2-9 (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

OH 38 (1984–2023) MI 28 (1980–2026) TX 23 (1986–2025) PA 22 (1976–2024) NY 21 (1986–2026) CA 20 (1967–2025) MD 19 (1980–2020) NJ 17 (1983–2021) GA 14 (1983–2020) MA 11 (1982–2018) IL 11 (1987–2018) MO 10 (1961–2020) WA 10 (1991–2021) FL 10 (1995–2019) IN 9 (1978–2016) LA 9 (1986–2021) KY 8 (1985–2026) AL 8 (1988–2025) MT 8 (1982–2017) MS 8 (1996–2024) NV 7 (1979–2025) CT 5 (1987–2010) VA 4 (1982–2006) NC 4 (1979–2022) MN 4 (2002–2016) WY 4 (1983–2022) NM 3 (2018–2026) CO 3 (1989–2006) DC 3 (1992–2009) HI 3 (1997–2018) AK 3 (2010–2024) KS 3 (1983–2022) WV 3 (1988–2002) SD 3 (1990–2016) TN 3 (1995–2004) OR 2 (1984–2024) NH 2 (2006–2025) ME 2 (2017–2026) IA 2 (1994–2001) WI 2 (2002–2003) ND 2 (1997–1997) AR 2 (1999–2021)

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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