prima facie case waiver (Wisconsin) · Go Syfert
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prima facie case waiver in Wisconsin

9 Wisconsin opinions name it 2 courts 1910–2023 2 in the last five years

The cases below were cited by Wisconsin 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 (1)

CaseFollowedCited
State v. Leegreen
wisctapp · 1993 · cited in 2 Wisconsin opinions naming this issue, 2021–2023
2 sentences

2023In the absence of countervailing evidence, once the [S]tate has established a prima facie case of waiver of Miranda rights and voluntariness of an in-custody statement, the statement should be admitted into evidence. …. “[T]he general rule is that a prima facie case will be established ‘when the [S]tate has established that [the] 14 No. 2021AP1581-CR defendant has been told or has read all the rights and admonitions required in Miranda, and the defendant indicates he [or she] understands them and is willing to make a statement.’” Lee, 175 Wis. 2d at 359-60 (citation omitted). ¶24 We agree with

2021“In the absence of countervailing evidence, once the state has established a prima facie case of waiver of Miranda rights and voluntariness of an in-custody statement, the statement should be admitted into evidence.” Lee, 175 Wis. 2d at 359 .

12

Distinguished, questioned or overruled (0)

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

Also cited on this issue (9)

CaseCitedYears
State v. Hernandez green
wis · 1973
2 sentences

1999In Mitchell , we stated, "Once the state has established a prima facie case of waiver of Miranda rights and voluntariness of a statement of an in-custody police interrogation in the absence of countervailing evidence, the statement should be admitted into evidence." Mitchell, 167 Wis. 2d at 696 (citing State v. Hernandez, 61 Wis. 2d 253, 259 , 212 N.W.2d 118 (1973))(emphasis added).

1999In Mitchell , we stated, "Once the state has established a prima facie case of waiver of Miranda rights and voluntariness of a statement of an in-custody police interrogation in the absence of countervailing evidence, the statement should be admitted into evidence." Mitchell, 167 Wis. 2d at 696 (citing State v. Hernandez, 61 Wis. 2d 253, 259 , 212 N.W.2d 118 (1973))(emphasis added).

31992–1999
State v. Mitchell green
wis · 1992
2 sentences

2008State v. Mitchell, 167 Wis. 2d 672, 696 , 482 N.W.2d 364 (1992). ¶ 37.

1999In Mitchell , we stated, "Once the state has established a prima facie case of waiver of Miranda rights and voluntariness of a statement of an in-custody police interrogation in the absence of countervailing evidence, the statement should be admitted into evidence." Mitchell, 167 Wis. 2d at 696 (citing State v. Hernandez, 61 Wis. 2d 253, 259 , 212 N.W.2d 118 (1973))(emphasis added).

21999–2008
Denny v. Mertz green
wis · 1982
2 sentences

2005Corp., 68 Wis. 2d 487, 499 , 228 N.W.2d 737 (1975) ("When the defendant has established a prima facie case of privilege, it ordinarily devolves upon the plaintiff to rebut this showing by proof of actual malice, want of good faith, or due care, etc." (Citations omitted; second emphasis added.)); Denny v. Mertz, 106 Wis. 2d 636, 674 , 318 N.W.2d 141 (1982) (Abrahamson, J., dissenting) (noting that although defamation is in general a strict liability tort, "the application of the doctrines of 'conditional privilege' and 'abuse of privilege' means that the law of defamation in operation is not a

2005Corp., 68 Wis. 2d 487, 499 , 228 N.W.2d 737 (1975) ("When the defendant has established a prima facie case of privilege, it ordinarily devolves upon the plaintiff to rebut this showing by proof of actual malice, want of good faith, or due care, etc." (Citations omitted; second emphasis added.)); Denny v. Mertz, 106 Wis. 2d 636, 674 , 318 N.W.2d 141 (1982) (Abrahamson, J., dissenting) (noting that although defamation is in general a strict liability tort, "the application of the doctrines of 'conditional privilege' and 'abuse of privilege' means that the law of defamation in operation is not a

12005–2005
Calero v. Del Chemical Corp. green
wis · 1975
2 sentences

2005Corp., 68 Wis. 2d 487, 499 , 228 N.W.2d 737 (1975) ("When the defendant has established a prima facie case of privilege, it ordinarily devolves upon the plaintiff to rebut this showing by proof of actual malice, want of good faith, or due care, etc." (Citations omitted; second emphasis added.)); Denny v. Mertz, 106 Wis. 2d 636, 674 , 318 N.W.2d 141 (1982) (Abrahamson, J., dissenting) (noting that although defamation is in general a strict liability tort, "the application of the doctrines of 'conditional privilege' and 'abuse of privilege' means that the law of defamation in operation is not a

2005Corp., 68 Wis. 2d 487, 499 , 228 N.W.2d 737 (1975) ("When the defendant has established a prima facie case of privilege, it ordinarily devolves upon the plaintiff to rebut this showing by proof of actual malice, want of good faith, or due care, etc." (Citations omitted; second emphasis added.)); Denny v. Mertz, 106 Wis. 2d 636, 674 , 318 N.W.2d 141 (1982) (Abrahamson, J., dissenting) (noting that although defamation is in general a strict liability tort, "the application of the doctrines of 'conditional privilege' and 'abuse of privilege' means that the law of defamation in operation is not a

12005–2005
State v. Parker green
wis · 1972
1 sentence

1978In Hernandez , at 259, we stated: “[A]s a generalization to the Miranda question . . . when the state has established that defendant has been told or has read all the rights and admonitions required in Miranda , and the defendant indicates he understands them and is willing to make a statement, a prima facie case (case is used in the limited sense of the issue at hand) has been established.” *81 While the state has the burden “to show beyond a reasonable doubt that statements or confessions are admissible, on review by this court the test is whether the findings by the trial court were contrar

11978–1978
State v. Scarbrough green
wis · 1972
1 sentence

1978In Hernandez , at 259, we stated: “[A]s a generalization to the Miranda question . . . when the state has established that defendant has been told or has read all the rights and admonitions required in Miranda , and the defendant indicates he understands them and is willing to make a statement, a prima facie case (case is used in the limited sense of the issue at hand) has been established.” *81 While the state has the burden “to show beyond a reasonable doubt that statements or confessions are admissible, on review by this court the test is whether the findings by the trial court were contrar

11978–1978
Dale v. Harris green
mass · 1872
1 sentence

1910Calkins v. Sumner, 13 Wis. 193 ; Hemmens v. Nelson, 138 N. Y. 517, 524 , 34 N. E. 342 ; Dale v. Harris, 109 Mass. 193 ; 8 Ency. of Ev. 220.

11910–1910
Hemmens v. . Nelson green
ny · 1893
2 sentences

1910Calkins v. Sumner, 13 Wis. 193 ; Hemmens v. Nelson, 138 N. Y. 517, 524 , 34 N. E. 342 ; Dale v. Harris, 109 Mass. 193 ; 8 Ency. of Ev. 220.

1910Calkins v. Sumner, 13 Wis. 193 ; Hemmens v. Nelson, 138 N. Y. 517, 524 , 34 N. E. 342 ; Dale v. Harris, 109 Mass. 193 ; 8 Ency. of Ev. 220.

11910–1910
Calkins v. Sumner green
wis · 1860
1 sentence

1910Calkins v. Sumner, 13 Wis. 193 ; Hemmens v. Nelson, 138 N. Y. 517, 524 , 34 N. E. 342 ; Dale v. Harris, 109 Mass. 193 ; 8 Ency. of Ev. 220.

11910–1910

Where else courts name it

IN 134 (1911–2018) NY 77 (1915–2026) TX 40 (1926–2024) IL 25 (1982–2024) NC 13 (1906–2017) OH 13 (1958–2025) WA 12 (1913–2017) CA 11 (1914–2019) MI 10 (1962–2024) MO 9 (1901–2021) WI 9 (1910–2023) LA 8 (2001–2024) PA 7 (1973–2026) TN 6 (1965–2024) ND 6 (2013–2026) FL 6 (1992–2013) IA 5 (2012–2023) AL 5 (1977–2006) CO 5 (1957–2013) MA 5 (1997–2020) AZ 5 (1985–2022) NJ 4 (1998–2024) NM 4 (2017–2024) AR 4 (1993–2000) DC 3 (1987–2007) UT 3 (1989–2003) OR 3 (1954–2010) HI 2 (1939–2016) CT 2 (2001–2002) WY 2 (1978–2007) KY 2 (1922–2017)

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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