residual hearsay exception in Illinois

8 Illinois opinions name it 2 courts 1999–2008 0 in the last five years

The cases below were cited by Illinois 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 (4)

Case	Followed	Cited
State v. Fischergreen nd · 1990 · cited in 2 Illinois opinions naming this issue, 2000–2000 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn , 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers , 957 F.2d 609 (8th Cir. 1992); State v. Christianson , 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State , 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before	2	2
United States v. Charles W. Blackburngreen ca7 · 1993 · cited in 2 Illinois opinions naming this issue, 2000–2000 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the	2	2
Helen L. Huff, Administratrix of the Estate of Jessee Huff, Deceased, Cross-Appellant v. White Motor Corporation, Cross-Appelleegreen ca7 · 1979 · cited in 1 Illinois opinions naming this issue, 2002–2002 1 sentence 2002E.g. , Huff v. White Motor Corp. , 609 F.2d 286, 291 (7th Cir. 1979); United States v. Fernandez , 892 F.2d 976, 982 (11th Cir. 1989) (only extraordinary grand jury testimony could possibly be admitted under rule) .	1	1
United States v. Antonio Fernandez, Jorge Recarey, Mariano Villa Del Raygreen ca11 · 1990 · cited in 1 Illinois opinions naming this issue, 2002–2002 1 sentence 2002E.g. , Huff v. White Motor Corp. , 609 F.2d 286, 291 (7th Cir. 1979); United States v. Fernandez , 892 F.2d 976, 982 (11th Cir. 1989) (only extraordinary grand jury testimony could possibly be admitted under rule) .	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (10)

Case	Cited	Years
People v. Drum green ill · 2000 2 sentences 2008Drum, 194 Ill. 2d at 491-92 . 2008Drum, 194 Ill.2d at 491-92 , 252 Ill.	3	2008–2008
State v. Christianson green me · 1979 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the	2	2000–2000
Paul A. Fischer v. Thomas Powers, Warden, North Dakota State Penitentiary neutral ca8 · 1992 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the	2	2000–2000
People v. Mayfield-Ulloa green coloctapp · 1991 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn , 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers , 957 F.2d 609 (8th Cir. 1992); State v. Christianson , 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State , 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before	2	2000–2000
Moon v. State green md · 1984 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the	2	2000–2000
State v. Kittrell green njsuperctappdiv · 1995 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the	2	2000–2000
State v. Hancock green or · 1993 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the	2	2000–2000
Zoerner v. State green miss · 1998 2 sentences 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir.1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir.1992); State v. Christianson, 404 A.2d 999 (Me.1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant's sixth amendment right where the statute requires that the tester be produced, upon the defendant's request, before the evi 2000See United States v. Blackburn, 992 F.2d 666 (7th Cir. 1993) (admissible under the residual hearsay exception); Fischer v. Powers, 957 F.2d 609 (8th Cir. 1992); State v. Christianson, 404 A.2d 999 (Me. 1979) (statute only requires that a defendant follow a notice procedure prior to trial if he wants the testing chemist to testify in person as a witness called by the prosecution); Moon v. State, 300 Md. 354 , 478 A.2d 695 (1984) (the legislature has safeguarded the defendant’s sixth amendment right where the statute requires that the tester be produced, upon the defendant’s request, before the	2	2000–2000
United States v. Christopher Clarke green ca4 · 1993 2 sentences 1999United States v. Dent, 984 F.2d 1453 (7th Cir. 1993) (the prior grand jury testimony did not have sufficient indicia of trustworthiness); United States v. Clarke, 2 F.3d 81 (4th Cir. 1993) (grand jury testimony does bear sufficient indicia of reliability). 1999United States v. Dent, 984 F.2d 1453 (7th Cir. 1993)(the prior grand jury testimony did not have sufficient indicia of trustworthiness); United States v. Clarke, 2 F.3d 81 (4th Cir. 1993)(grand jury testimony does bear sufficient indicia of reliability).	2	1999–1999
United States v. Charles Dent, Also Known as William Brown, and Ivy T. Tucker green ca7 · 1993 2 sentences 1999United States v. Dent, 984 F.2d 1453 (7th Cir. 1993) (the prior grand jury testimony did not have sufficient indicia of trustworthiness); United States v. Clarke, 2 F.3d 81 (4th Cir. 1993) (grand jury testimony does bear sufficient indicia of reliability). 1999United States v. Dent, 984 F.2d 1453 (7th Cir. 1993)(the prior grand jury testimony did not have sufficient indicia of trustworthiness); United States v. Clarke, 2 F.3d 81 (4th Cir. 1993)(grand jury testimony does bear sufficient indicia of reliability).	2	1999–1999

Where else courts name it

NE 65 (1990–2026) GA 32 (2016–2026) NC 32 (1987–2025) CO 25 (1984–2026) WI 25 (1988–2026) MN 16 (1991–2024) IA 15 (2001–2026) AR 11 (1990–2026) OR 9 (1987–2024) IL 8 (1999–2008) AZ 6 (1988–2024) MI 6 (2002–2023) UT 6 (2005–2026) SD 5 (1993–2010) NJ 5 (1988–2021) AK 5 (1995–2023) CT 4 (2010–2022) WV 4 (1990–2011) MS 3 (2004–2011) MO 3 (1997–2013) MD 3 (1995–2020) MT 3 (1999–2001) NV 3 (2005–2019) HI 2 (2003–2005) KY 2 (1988–1988) NM 2 (1992–2010) IN 2 (2004–2005) CA 2 (2003–2014)

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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