modern rule (Alaska) · Go Syfert
← Alaska issues

modern rule in Alaska

8 Alaska opinions name it 2 courts 1970–2011 0 in the last five years

The cases below were cited by Alaska 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 (23)

CaseFollowedCited
Shortt v. Lasswellgreen
moctapp · 1989 · cited in 2 Alaska opinions naming this issue, 1998–1998
2 sentences

1998Compare, e.g., Shortt v. Lasswell, 765 S.W.2d 387 (Mo. App. 1989).

1998Compare, e.g., Shortt v. Lasswell, 765 S.W.2d 387 (Mo.App.1989).

22
Thompson v. Stategreen
alaskactapp · 2009 · cited in 1 Alaska opinions naming this issue, 2011–2011
1 sentence

2011The State relies on this Court's decision in Thompson v. State, 210 P.3d 1233, 1238-39 (Alaska App.2009), where we stated that "the modern test for authentication [of an audio recording] is whether the proponent of the evidence has presented sufficient evidence to support a rational finding that the . recording is authentic".

11
Kaps Transport, Inc. v. Henrygreen
alaska · 1977 · cited in 1 Alaska opinions naming this issue, 2009–2009
1 sentence

2009See Johnson v. State, 636 P.2d 47, 67 (Alaska 1981), and Kaps Transport, Inc. v. Henry, 572 P.2d 72, 75-76 (Alaska 1977), both holding that the admissibility of photographic evidence hinges on whether the proponent of the evidence can establish that the photograph accurately depicts its subject.) With regard to the two tape-recorded conversations at issue in Thompson's case, the State presented testimony to support the conclusions (1) that A.D.'s mother engaged Thompson in conversation about his relationship with A.D., (2) that A.D.'s mother recorded two of these conversations, and (8) that sh

11
Johnson v. Stategreen
alaska · 1981 · cited in 1 Alaska opinions naming this issue, 2009–2009
1 sentence

2009See Johnson v. State, 636 P.2d 47, 67 (Alaska 1981), and Kaps Transport, Inc. v. Henry, 572 P.2d 72, 75-76 (Alaska 1977), both holding that the admissibility of photographic evidence hinges on whether the proponent of the evidence can establish that the photograph accurately depicts its subject.) With regard to the two tape-recorded conversations at issue in Thompson's case, the State presented testimony to support the conclusions (1) that A.D.'s mother engaged Thompson in conversation about his relationship with A.D., (2) that A.D.'s mother recorded two of these conversations, and (8) that sh

11
Litsey v. District Courtgreen
colo · 1977 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
In Re Application of Smigelskigreen
nj · 1959 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Wilsongreen
mont · 1996 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
Elkins v. Stategreen
indctapp · 1995 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Randolphgreen
neb · 1971 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Cummingsgreen
nd · 1986 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
In Re Estradagreen
cal · 1965 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Pardongreen
nc · 1967 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. MacArelligreen
ri · 1977 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Andrewsgreen
alaskactapp · 1985 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006State v. Andrews, 707 P.2d 900, 907 (Alaska App.1985), opinion adopted by State v. Andrews, 723 P.2d 85, 86 (Alaska 1986); see also Wells v. State, 706 P.2d 711,713 (Alaska App.1985) ("It is well established that, in accordance with the rule of lenity, ambiguities in penal statutes must be resolved in favor of the accused.”). 44 .

11
State v. Tappgreen
utah · 1971 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
People v. Schultzgreen
mich · 1990 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Coolidgegreen
minn · 1979 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Wiesegreen
iowa · 1972 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
Wells v. Stategreen
alaskactapp · 1985 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006State v. Andrews, 707 P.2d 900, 907 (Alaska App.1985), opinion adopted by State v. Andrews, 723 P.2d 85, 86 (Alaska 1986); see also Wells v. State, 706 P.2d 711,713 (Alaska App.1985) ("It is well established that, in accordance with the rule of lenity, ambiguities in penal statutes must be resolved in favor of the accused.”). 44 .

11
State v. Von Gelderngreen
haw · 1981 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

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People v. Olivergreen
ny · 1956 · cited in 1 Alaska opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

2006See, e.g., Estrada, 48 Cal.Rptr. 172 , 408 P.2d at 953 ("A legislative mitigation of the penalty for a particular crime represents a legislative judgment that the lesser penalty or the different treatment is sufficient to meet the legitimate ends of the criminal law.... [I]t is safe to assume, as the modern rule does, that it was the legislative design that the lighter penalty should be imposed in all cases that subsequently reach the courts.”); Litsey v. District Court, 193 Colo. 341 , 565 P.2d 1343, 1344 (1977) (defendant was entitled to the benefit of change in law reducing look-back for pr

11
State v. Andrewsgreen
alaska · 1986 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006State v. Andrews, 707 P.2d 900, 907 (Alaska App.1985), opinion adopted by State v. Andrews, 723 P.2d 85, 86 (Alaska 1986); see also Wells v. State, 706 P.2d 711,713 (Alaska App.1985) ("It is well established that, in accordance with the rule of lenity, ambiguities in penal statutes must be resolved in favor of the accused.”). 44 .

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Comer Blocker v. United Statesgreen
cadc · 1961 · cited in 1 Alaska opinions naming this issue, 1970–1970
2 sentences

1970For example, the use of the term "product" created difficult problems of causation. [20] And as Judge (now Chief Justice) Burger complained, concurring in Blocker v. United States, 110 U.S.App.D.C. 41 , 288 F.2d 853, 860 (1960), the test in many cases put the legal determination in the hands of psychiatric witnesses rather than judge and jury.

1970For example, the use of the term "product" created difficult problems of causation. [20] And as Judge (now Chief Justice) Burger complained, concurring in Blocker v. United States, 110 U.S.App.D.C. 41 , 288 F.2d 853, 860 (1960), the test in many cases put the legal determination in the hands of psychiatric witnesses rather than judge and jury.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
MacPherson v. . Buick Motor Co. green
ny · 1916
2 sentences

1998In those jurisdictions, a contractor is immune from liability under the "completion and acceptance doctrine": "`[W]here the work of an independent contractor is completed, turned over to, and accepted by the owner, the contractor is not liable to third persons for damages or injuries subsequently suffered by reason of the condition of the work, even though he was negligent in carrying out the contract.'" [9] This historically was the common law rule, but it has been so riddled with exceptions that most courts have now adopted the modern rule reflected in Restatement (Second) of Torts § 385 (19

1998In those jurisdictions, a contractor is immune from liability under the "completion and acceptance doctrine": "`[W]here the work of an independent contractor is completed, turned over to, and accepted by the owner, the contractor is not liable to third persons for damages or injuries subsequently suffered by reason of the condition of the work, even though he was negligent in carrying out the contract.'" [9] This historically was the common law rule, but it has been so riddled with exceptions that most courts have now adopted the modern rule reflected in Restatement (Second) of Torts § 385 (19

21998–1998

Where else courts name it

CA 141 (1885–2026) NY 88 (1806–2025) PA 79 (1855–2024) IN 60 (1874–2024) MO 59 (1892–2025) IL 53 (1868–2013) TX 48 (1913–2022) TN 41 (1875–2025) IA 41 (1871–2021) MD 40 (1964–2025) MI 40 (1879–2023) NC 39 (1893–2022) WA 38 (1901–2024) CT 36 (1917–2022) KY 36 (1857–2025) OH 33 (1894–2026) AL 32 (1876–2026) CO 31 (1896–2023) NJ 31 (1832–2025) AZ 31 (1922–2018) OK 30 (1913–2004) KS 29 (1893–2024) WV 28 (1893–2013) VA 24 (1882–2026) NM 24 (1904–2024) OR 21 (1871–2014) WI 20 (1900–2021) FL 20 (1931–2017) LA 17 (1871–2020) MS 17 (1904–1998) MA 17 (1906–2025) NE 16 (1888–1981) MN 15 (1875–2024) DC 12 (1976–2011) ND 12 (1893–1980) DE 11 (1900–2018) HI 11 (1921–2011) ME 11 (1903–2020) AR 10 (1907–2010) UT 9 (1912–2019) MT 9 (1899–1936) SC 9 (1927–2023) WY 8 (1933–2013) GA 8 (1848–2010) AK 8 (1970–2011) ID 7 (1909–1992) SD 7 (1890–2007) NH 6 (1974–2024) VT 5 (1932–2025) RI 5 (1901–1983) NV 4 (1910–1932) VI 2 (1991–1998)

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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