relevance analysis (Missouri) · Go Syfert
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relevance analysis in Missouri

9 Missouri opinions name it 2 courts 1921–2023 1 in the last five years

The cases below were cited by Missouri 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 (6)

CaseFollowedCited
State v. Jonesgreen
mo · 1986 · cited in 2 Missouri opinions naming this issue, 2016–2020
2 sentences

2020Even then, section 491.015.2 provides that "[e]vidence of the sexual conduct of the complaining witness offered under this section is admissible to the extent that the court finds the evidence relevant to a material fact or issue." See State v. Jones, 716 S.W.2d 799, 800 (Mo. banc 1986) (holding that "subsection 2 [of section 491.015] is directed only at the exceptions set forth in [section 491.015.1] (1), (2), (3), and (4)," such that evidence offered under the exceptions to section 491.015.1 is admissible "only 'to the extent that the court finds [it] relevant to a material fact or issue'");

2016Jones, 716 S.W.2d at 800 .

12
State v. Williamsgreen
moctapp · 1993 · cited in 2 Missouri opinions naming this issue, 2018–2019
2 sentences

2019We analyze relevance under Section 490.065.2 using “substantively the same relevance analysis our courts have been employing, particularly in child[-]sex cases: whether ‘the subject of such testimony is one upon which the jurors, for want of experience or knowledge, would otherwise be incapable of drawing a proper conclusion from the facts in evidence.’” Wright, 562 S.W.3d at 319 (quoting State v. Baker, 422 S.W.3d 508, 513 (Mo. App. E.D. 2014)); see also State v. Williams, 858 S.W.2d 796, 798 (Mo. App. E.D. 1993).

2018This is substantively the same relevance analysis our courts have been employing, particularly in child sex cases: whether "the subject of such testimony is one upon which the jurors, for want of experience or knowledge, would otherwise be incapable of drawing a proper conclusion from the facts in evidence." Williams, 858 S.W.2d at 798 .

12
State v. Longgreen
mo · 2004 · cited in 2 Missouri opinions naming this issue, 2008–2008
2 sentences

2008The fact that the allegations involved a different type of abuse is a factor that the trial court can properly consider when determining relevance, however. “[Sjimilarities between the prior false allegation and the charged offense as well as circumstances under which the allegation was made all factor into the relevance analysis.” Long, 140 S.W.3d at 31 .

2008See id. at 31 (“similarities between the prior false allegation and the charged offense as well as circumstances under which the allegation was made all factor into the relevance analysis”).

12
State of Missouri v. Antonio Rycrawgreen
moctapp · 2016 · cited in 1 Missouri opinions naming this issue, 2020–2020
1 sentence

2020Even then, section 491.015.2 provides that "[e]vidence of the sexual conduct of the complaining witness offered under this section is admissible to the extent that the court finds the evidence relevant to a material fact or issue." See State v. Jones, 716 S.W.2d 799, 800 (Mo. banc 1986) (holding that "subsection 2 [of section 491.015] is directed only at the exceptions set forth in [section 491.015.1] (1), (2), (3), and (4)," such that evidence offered under the exceptions to section 491.015.1 is admissible "only 'to the extent that the court finds [it] relevant to a material fact or issue'");

11
State of Missouri v. Alan John Gormangreen
moctapp · 2015 · cited in 1 Missouri opinions naming this issue, 2020–2020
1 sentence

2020Even then, section 491.015.2 provides that "[e]vidence of the sexual conduct of the complaining witness offered under this section is admissible to the extent that the court finds the evidence relevant to a material fact or issue." See State v. Jones, 716 S.W.2d 799, 800 (Mo. banc 1986) (holding that "subsection 2 [of section 491.015] is directed only at the exceptions set forth in [section 491.015.1] (1), (2), (3), and (4)," such that evidence offered under the exceptions to section 491.015.1 is admissible "only 'to the extent that the court finds [it] relevant to a material fact or issue'");

11
State of Missouri, Plaintiff/Respondent v. Robert Bakergreen
moctapp · 2014 · cited in 1 Missouri opinions naming this issue, 2019–2019
1 sentence

2019We analyze relevance under Section 490.065.2 using “substantively the same relevance analysis our courts have been employing, particularly in child[-]sex cases: whether ‘the subject of such testimony is one upon which the jurors, for want of experience or knowledge, would otherwise be incapable of drawing a proper conclusion from the facts in evidence.’” Wright, 562 S.W.3d at 319 (quoting State v. Baker, 422 S.W.3d 508, 513 (Mo. App. E.D. 2014)); see also State v. Williams, 858 S.W.2d 796, 798 (Mo. App. E.D. 1993).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
State v. Williams green
mo · 2018
1 sentence

2023In Williams, the Court set out factors that illustrate the legal analysis required 9 by the constitutional provision, but cautioned that the relevance of these factors will vary depending on the case, “as will the weight to be afforded any one factor in particular.” Id.

12023–2023
State v. Wright green
moctapp · 2018
2 sentences

2019We analyze relevance under Section 490.065.2 using “substantively the same relevance analysis our courts have been employing, particularly in child[-]sex cases: whether ‘the subject of such testimony is one upon which the jurors, for want of experience or knowledge, would otherwise be incapable of drawing a proper conclusion from the facts in evidence.’” Wright, 562 S.W.3d at 319 (quoting State v. Baker, 422 S.W.3d 508, 513 (Mo. App. E.D. 2014)); see also State v. Williams, 858 S.W.2d 796, 798 (Mo. App. E.D. 1993).

2019Under this standard, Missouri courts long have recognized “that generalized testimony about the behaviors of children alleging sexual abuse is specialized knowledge and that it is helpful to juries.” Id. 3 The recent “me too” movement involves “adult women disclosing sexual assaults from years earlier.” Wright, 562 S.W.3d at 314 . 12 “In cases where the sexual abuse of a child is at issue, there are two types of testimony that are typically at the forefront of a challenge against an expert witness—generalized and particular.” McWilliams, 564 S.W.3d at 626 .

12019–2019
State v. McWilliams green
moctapp · 2018
1 sentence

2019Under this standard, Missouri courts long have recognized “that generalized testimony about the behaviors of children alleging sexual abuse is specialized knowledge and that it is helpful to juries.” Id. 3 The recent “me too” movement involves “adult women disclosing sexual assaults from years earlier.” Wright, 562 S.W.3d at 314 . 12 “In cases where the sexual abuse of a child is at issue, there are two types of testimony that are typically at the forefront of a challenge against an expert witness—generalized and particular.” McWilliams, 564 S.W.3d at 626 .

12019–2019
State v. Celis-Garcia green
mo · 2011
1 sentence

2016We note a difference in our standard of review from Celis-Garcia, where the instructional error was unpreserved and reviewed under our plain-error standard. 344 S.W.3d at 158-59 .

12016–2016
Bequette v. State green
moctapp · 2005
1 sentence

2006Id.

12006–2006
Little v. Harrington green
mo · 1880
1 sentence

1921The earliest of the cases cited in the Meyer Case on the point is Little v. Harrington, 71 Mo. 390 , in which it was held that the then existing sections of the statutes (Secs. 3513 and 3522, R.

11921–1921

Where else courts name it

TX 61 (1998–2025) CA 43 (1963–2026) GA 26 (1988–2025) IL 21 (1975–2024) WA 20 (1987–2026) PA 16 (2003–2025) NJ 15 (1973–2024) OR 13 (1981–2021) NC 11 (1989–2019) MA 11 (1980–2018) UT 11 (2002–2026) FL 10 (1978–2019) DC 10 (1996–2021) MO 9 (1921–2023) MD 9 (1979–2025) CT 9 (1994–2025) ID 8 (1977–2023) OH 8 (2005–2025) WI 6 (1977–2025) AZ 5 (2000–2015) IN 5 (1974–2007) CO 4 (1993–2025) IA 4 (2010–2017) MN 4 (1997–2008) DE 4 (1997–2007) MI 4 (2001–2026) NE 4 (1992–2019) VA 4 (1994–2025) KS 4 (2009–2026) MS 4 (2001–2024) AL 3 (1991–1999) KY 3 (2016–2025) AK 3 (1981–2020) VT 3 (1988–2003) TN 3 (1988–2019) NH 2 (1995–2016) NY 2 (1985–2018) LA 2 (1988–2001) WY 2 (1999–2017) HI 2 (2000–2020)

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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