Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
9 Minnesota opinions name it 2 courts 1996–2024 1 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.
| Case | Followed | Cited |
|---|---|---|
Huebbe v. Dairy Farmers of Americagreen2 sentences2024First, “for the statement-against-interest exception to apply, the declarant must be unavailable.” Miles v. State, 840 N.W.2d 195, 203 (Minn. 2013); see also Minn. R. 2015We conclude that the district court did not abuse its discretion by excluding C.J.’s statement under the statement-against-interest exception to the hearsay rule because Richards has not shown that the statement is “trustworthy by independent corroborating evidence that bespeaks reliability.” See Miles v. State, 840 N.W.2d 195, 203 (Minn. 2013). | 2 | 2 |
State v. Dukesgreen2 sentences2001E.g., State v. Aubid, 591 N.W.2d 472, 480 (Minn.1999); State v. Dukes, 544 N.W.2d 13, 19 (Minn. 1996). 1996See State v. Dukes, 544 N.W.2d 13, 18-19 (Minn.1996) (under Williamson v. United States, 512 U.S. 594 , -, 114 S.Ct. 2431, 2435 , 129 L.Ed.2d 476 (1994), the statement against interest exception “does not allow the admission of non-self-inculpatory statements even in the broader context of a generally self-inculpatory narrative”). 2 . | 2 | 2 |
Williamson v. United Statesgreen2 sentences2010In Williamson v. United States, the Supreme Court concluded that the word “statement,” as used in the statement-against-interest exception, of the Fed.R.Evid. 804(b)(3), should be narrowly construed as “a single declaration or remark” rather than an entire confession narrative. 512 U.S. 594, 599 , 114 S.Ct. 2431 , 129 L.Ed.2d 476 (1994) (citation omitted) (internal quotation marks omitted); see also Jones, 556 N.W.2d at 908 . 2010In Williamson v. United States, the Supreme Court concluded that the word “statement,” as used in the statement-against-interest exception, of the Fed.R.Evid. 804(b)(3), should be narrowly construed as “a single declaration or remark” rather than an entire confession narrative. 512 U.S. 594, 599 , 114 S.Ct. 2431 , 129 L.Ed.2d 476 (1994) (citation omitted) (internal quotation marks omitted); see also Jones, 556 N.W.2d at 908 . | 1 | 3 |
State v. Hurdgreen2 sentences2016Evid. 804(b)(3); see also State v. Hurd, 763 N.W.2d 17, 34-35 (Minn.2009) (explaining that the statement-against-interest exception applies , to statements exculpating the. accused only when the declaration against interest is proven trustworthy by independent, corroborating evidence). 2016Evid. 804(b)(3); see also State v. Hurd, 763 N.W.2d 17, 34-35 (Minn. 2009) (explaining that the statement-against-interest exception applies to statements exculpating the accused only when the declaration against interest is proven trustworthy by independent corroborating evidence). | 1 | 2 |
Ferguson v. Stategreen1 sentence2016To determine whether the “corroborating circumstances” requirement of Rule 804(b)(3) is satisfied, we have considered the following factors: (1) whether other evidence corroborates the facts in the hearsay statement; (2) the extent to which the hearsay statement is consistent with the declarant’s prior testimony and other statements; (3) the relationship between the declarant and other witnesses and parties, including the defendant; (4) whether the declarant has reason to fabricate the statement; (5) the overall credibility and character of the declarant; and (6) the timing of the statement. 8 | 1 | 1 |
State v. Jonesgreen2 sentences2010In Williamson v. United States, the Supreme Court concluded that the word “statement,” as used in the statement-against-interest exception, of the Fed.R.Evid. 804(b)(3), should be narrowly construed as “a single declaration or remark” rather than an entire confession narrative. 512 U.S. 594, 599 , 114 S.Ct. 2431 , 129 L.Ed.2d 476 (1994) (citation omitted) (internal quotation marks omitted); see also Jones, 556 N.W.2d at 908 . 2010In Williamson v. United States, the Supreme Court concluded that the word "statement," as used in the statement-against-interest exception, of the Fed.R.Evid. 804(b)(3), should be narrowly construed as "a single declaration or remark" rather than an entire confession narrative. 512 U.S. 594, 599 , 114 S.Ct. 2431 , 129 L.Ed.2d 476 (1994) (citation omitted) (internal quotation marks omitted); see also Jones, 556 N.W.2d at 908 . | 1 | 1 |
State v. Glazegreen1 sentence2009See also State v. Glaze, 452 N.W.2d 655, 661 (Minn.1990) (affirming exclusion of confession from unavailable third party perpetrator because record did not contain evidence corroborating the confession). | 1 | 1 |
State v. Aubidgreen2 sentences2001E.g., State v. Aubid, 591 N.W.2d 472, 480 (Minn.1999); State v. Dukes, 544 N.W.2d 13, 19 (Minn.1996). 2001E.g., State v. Aubid, 591 N.W.2d 472, 480 (Minn.1999); State v. Dukes, 544 N.W.2d 13, 19 (Minn. 1996). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Lilly v. Virginia
green
2 sentences2001In 1999, a plurality of the Supreme Court concluded that the statement against interest exception to the hearsay rule, found in Fed.R.Evid. 804(b)(3), is not a "firmly-rooted" exception for purposes of Confrontation Clause analysis. [3] Lilly, 527 U.S. at 134 , 119 S.Ct. 1887 . 2001In 1999, a plurality of the Supreme Court concluded that the statement against interest exception to the hearsay rule, found in Fed.R.Evid. 804(b)(3), is not a "firmly-rooted" exception for purposes of Confrontation Clause analysis. [3] Lilly, 527 U.S. at 134 , 119 S.Ct. 1887 . | 2 | 2001–2010 |
Ohio v. Roberts
red
2 sentences2010Applying the now-discarded rule from Ohio v. Roberts, 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980), the Court determined that the statement-against-interest exception was not a "firmly rooted” hearsay exception. 2010Applying the now-discarded rule from Ohio v. Roberts, 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980), the Court determined that the statement-against-interest exception was not a "firmly rooted” hearsay exception. | 1 | 2010–2010 |
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.
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.