Crawford rule (North Carolina) · Go Syfert
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Crawford rule in North Carolina

9 North Carolina opinions name it 2 courts 2005–2023 3 in the last five years

The cases below were cited by North Carolina 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 (3)

CaseFollowedCited
Delaware v. Fensterergreen
scotus · 1985 · cited in 2 North Carolina opinions naming this issue, 2022–2022
2 sentences

2022Delaware v. Fensterer, 474 U.S. 15, 20 , 106 S. Ct. 292, 294 , 88 L.

2022Delaware v. Fensterer, 474 U.S. 15, 20 , 106 S. Ct. 292, 294 , 88 L.

22
Whorton v. Bocktinggreen
scotus · 2007 · cited in 1 North Carolina opinions naming this issue, 2013–2013
2 sentences

2013See also Whorton v. Bockting, 549 U.S. 406, 416 , 127 S. Ct. 1173, 1181 (2007) (“The Crawford rule is flatly inconsistent with the prior governing precedent, Roberts, which Crawford overruled.”).

2013See also Whorton v. Bockting, 549 U.S. 406, 416 , 127 S. Ct. 1173, 1181 (2007) (“The Crawford rule is flatly inconsistent with the prior governing precedent, Roberts, which Crawford overruled.”).

11
Parker v. Pittmangreen
ncctapp · 1973 · cited in 1 North Carolina opinions naming this issue, 2012–2012
2 sentences

2012App. _, 697 S.E.2d 526 , 2010 WL 2651630 , at *2 (2010) (unpublished) (citing the Crawford rule as stated in Smith and affirming trial court’s order reforming the deed based on mutual mistake); Parker v. Pittman, 18 N.C.

2012App. _, 697 S.E.2d 526 , 2010 WL 2651630 , at *2 (2010) (unpublished) (citing the Crawford rule as stated in Smith and affirming trial court’s order reforming the deed based on mutual mistake); Parker v. Pittman, 18 N.C.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (9)

CaseCitedYears
Crawford v. Washington green
scotus · 2004
2 sentences

2023Had defendant’s case proceeded to trial and the same statement was admitted in furtherance of a conviction, without an opportunity to confront the witness, Crawford’s analysis and definitional application would be relevant. 541 U.S. at 68– 69, 124 S. Ct. at 1374 .

2023Had defendant’s case proceeded to trial and the same statement was admitted in furtherance of a conviction, without an opportunity to confront the witness, Crawford’s analysis and definitional application would be relevant. 541 U.S. at 68– 69, 124 S. Ct. at 1374 .

32006–2023
Ohio v. Roberts red
scotus · 1980
2 sentences

2013While application of the Crawford rule depends on which statements qualify as testimonial hearsay, the Court declined to “spell out a comprehensive definition of ‘testimonial.’ ” Id. at 68 , 124 S. Ct. at 1374 .

2013While application of the Crawford rule depends on which statements qualify as testimonial hearsay, the Court declined to “spell out a comprehensive definition of ‘testimonial.’ ” Id. at 68 , 124 S. Ct. at 1374 .

22005–2013
State v. Fair green
nc · 2001
2 sentences

2013Relying on Fair and Huffstetler, the majority concludes that because “ ‘[i]t is the expert opinion itself, not its underlying factual basis, that constitutes substantive evidence,’ ” Fair, 354 N.C. at 162 , 557 S.E.2d at 522 , and that so long as the information relied upon by the testifying expert “[allows] the factfinder ‘to understand the basis for the expert’s opinion and to determine whether that opinion should be found credible,’ ” Huffstetler, 312 N.C. at 108 , 322 S.E.2d at 121 , there is no Confrontation Clause violation.

2013Relying on Fair and Huffstetler, the majority concludes that because “ ‘[i]t is the expert opinion itself, not its underlying factual basis, that constitutes substantive evidence,’ ” Fair, 354 N.C. at 162 , 557 S.E.2d at 522 , and that so long as the information relied upon by the testifying expert “[allows] the factfinder ‘to understand the basis for the expert’s opinion and to determine whether that opinion should be found credible,’ ” Huffstetler, 312 N.C. at 108 , 322 S.E.2d at 121 , there is no Confrontation Clause violation.

12013–2013
State v. Huffstetler green
nc · 1984
2 sentences

2013Relying on Fair and Huffstetler, the majority concludes that because “ ‘[i]t is the expert opinion itself, not its underlying factual basis, that constitutes substantive evidence,’ ” Fair, 354 N.C. at 162 , 557 S.E.2d at 522 , and that so long as the information relied upon by the testifying expert “[allows] the factfinder ‘to understand the basis for the expert’s opinion and to determine whether that opinion should be found credible,’ ” Huffstetler, 312 N.C. at 108 , 322 S.E.2d at 121 , there is no Confrontation Clause violation.

2013Relying on Fair and Huffstetler, the majority concludes that because “ ‘[i]t is the expert opinion itself, not its underlying factual basis, that constitutes substantive evidence,’ ” Fair, 354 N.C. at 162 , 557 S.E.2d at 522 , and that so long as the information relied upon by the testifying expert “[allows] the factfinder ‘to understand the basis for the expert’s opinion and to determine whether that opinion should be found credible,’ ” Huffstetler, 312 N.C. at 108 , 322 S.E.2d at 121 , there is no Confrontation Clause violation.

12013–2013
State v. Puckett neutral
ncctapp · 2010
2 sentences

2012App. _, 697 S.E.2d 526 , 2010 WL 2651630 , at *2 (2010) (unpublished) (citing the Crawford rule as stated in Smith and affirming trial court’s order reforming the deed based on mutual mistake); Parker v. Pittman, 18 N.C.

2012App. _, 697 S.E.2d 526 , 2010 WL 2651630 , at *2 (2010) (unpublished) (citing the Crawford rule as stated in Smith and affirming trial court’s order reforming the deed based on mutual mistake); Parker v. Pittman, 18 N.C.

12012–2012
State v. Mobley green
ncctapp · 2009
2 sentences

2010Therefore, the analysts must be available for cross-examination by the defendant, or the evidence would be inadmissible absent a showing of unavailability and a prior opportunity by the defendant to cross-examine the analysts.” Id. at -, 684 S.E.2d at 510-11 .

2010Therefore, the analysts must be available for cross-examination by the defendant, or the evidence would be inadmissible absent a showing of unavailability and a prior opportunity by the defendant to cross-examine the analysts.” Id. at -, 684 S.E.2d at 510-11 .

12010–2010
State v. Christmas green
nc · 2004
2 sentences

2005App. 279, 283 , 598 S.E.2d 213, 217 , disc. review denied, 358 N.C. 734 , 601 S.E.2d 866 (2004).

2005App. 279, 283 , 598 S.E.2d 213, 217 , disc. review denied, 358 N.C. 734 , 601 S.E.2d 866 (2004).

12005–2005
State v. Clark green
nc · 2004
2 sentences

2005App. 279, 283 , 598 S.E.2d 213, 217 , disc. review denied, 358 N.C. 734 , 601 S.E.2d 866 (2004).

2005App. 279, 283 , 598 S.E.2d 213, 217 , disc. review denied, 358 N.C. 734 , 601 S.E.2d 866 (2004).

12005–2005
State v. Clark green
ncctapp · 2004
2 sentences

2005In analyzing a Crawford claim, we must determine: “(1) whether the evidence admitted was testimonial in nature; (2) whether the trial court properly ruled the declarant was unavailable; and (3) whether defendant had an opportunity to cross-examine the declarant.” State v. Clark, 165 N.C.

2005In analyzing a Crawford claim, we must determine: “(1) whether the evidence admitted was testimonial in nature; (2) whether the trial court properly ruled the declarant was unavailable; and (3) whether defendant had an opportunity to cross-examine the declarant.” State v. Clark, 165 N.C.

12005–2005

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 8C-1 (5)

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

TX 141 (1996–2025) CA 128 (1982–2026) NY 61 (1988–2026) IL 49 (1999–2021) FL 33 (2002–2019) OH 27 (2002–2025) GA 27 (1993–2025) WA 22 (1999–2012) CT 21 (1995–2025) TN 20 (1982–2025) PA 18 (1984–2026) MI 17 (1980–2020) OR 17 (2004–2015) LA 16 (1992–2014) VA 15 (2004–2023) MN 14 (2005–2018) KY 14 (2006–2025) MS 14 (1994–2016) NM 12 (2004–2022) WI 11 (2005–2022) KS 11 (1994–2014) MD 11 (2006–2021) MA 10 (2005–2018) CO 9 (2004–2025) IN 9 (2004–2017) NC 9 (2005–2023) NJ 9 (2007–2021) MO 8 (1997–2019) NH 7 (2007–2019) MT 6 (2002–2021) NV 5 (2009–2026) AZ 5 (2005–2019) IA 4 (2009–2022) DC 4 (2007–2012) WV 4 (2009–2021) SC 4 (2005–2014) ID 4 (2006–2015) AL 4 (2005–2014) AK 3 (2006–2021) AR 3 (2005–2015) OK 2 (2009–2012) HI 2 (2005–2007) UT 2 (1997–2005) SD 2 (2007–2018) DE 2 (2006–2017)

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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