federal confrontation clause (Oregon) · Go Syfert
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federal confrontation clause in Oregon

8 Oregon opinions name it 2 courts 1979–2024 1 in the last five years

The cases below were cited by Oregon 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 (7)

CaseFollowedCited
Ohio v. Robertsred
scotus · 1980 · cited in 3 Oregon opinions naming this issue, 1992–2024
2 sentences

2024See State v. Cook, 340 Or 530, 540 , 135 P3d 260 (2006) (explaining that, even though the United State Supreme Court no longer adheres to the test abrogated by Crawford, Oregon’s constitutional confrontation rights are governed by the earlier rule, announced in Ohio v. Roberts, 448 US 56 , 100 S Ct 2531 , 65 L Ed 2d 597 (1980), which required both witness unavailability and a firmly rooted hearsay excep- tion).

2024See State v. Cook, 340 Or 530, 540 , 135 P3d 260 (2006) (explaining that, even though the United State Supreme Court no longer adheres to the test abrogated by Crawford, Oregon’s constitutional confrontation rights are governed by the earlier rule, announced in Ohio v. Roberts, 448 US 56 , 100 S Ct 2531 , 65 L Ed 2d 597 (1980), which required both witness unavailability and a firmly rooted hearsay excep- tion).

23
State v. Campbellgreen
or · 1985 · cited in 2 Oregon opinions naming this issue, 1992–1999
2 sentences

1999In reaching its decision, the Court did not attempt “to map out a theory of the Confrontation Clause that would determine the validity of all * * * hearsay exceptions.” Id. at 64-65 (quoting California v. Green, 399 US 149, 162 , 90 S Ct 1930 , 26 L Ed 2d 489 (1970)) (internal quotation marks omitted).

1999In reaching its decision, the Court did not attempt "to map out a theory of the Confrontation Clause that would determine the validity of all * * * hearsay exceptions." Id. at 64-65 , 100 S.Ct. 2531 (quoting California v. Green, 399 U.S. 149, 162 , 90 S.Ct. 1930 , 26 L.Ed.2d 489 (1970)) (internal quotation marks omitted).

12
Gomez v. Stategreen
texapp · 2005 · cited in 1 Oregon opinions naming this issue, 2018–2018
1 sentence

2018As such, none of the statements admitted * * * were improper under Crawford ."); Gomez v. State , 183 S.W.3d 86 , 90 (Tex. Crim.

11
Robinson v. Stategreen
gactapp · 2005 · cited in 1 Oregon opinions naming this issue, 2018–2018
2 sentences

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

11
State v. Testergreen
vt · 2006 · cited in 1 Oregon opinions naming this issue, 2018–2018
2 sentences

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

11
State v. Moengreen
or · 1990 · cited in 1 Oregon opinions naming this issue, 1992–1992
2 sentences

1992Compare State v. Campbell, 299 Or 633, 652 , 705 P2d 694 (1985) (“before any out-of-court declaration of any available living witness *683 maybe offered against a defendant in a criminal trial, the witness must be produced and declared incompetent by the court to satisfy either Article I, section 11, of the Oregon Constitution, or the Sixth Amendment to the United States Constitution”) with State v. Moen, 309 Or 45, 62 , 786 P2d 111 (1990) (citing State v. Campbell as adopting the test in Ohio v. Roberts, 448 US 56 , 100 S Ct 2531 ,65 LEd 2d 597 (1980), that “ ‘[i]n the usual case,’ the declar

1992Compare State v. Campbell, 299 Or 633, 652 , 705 P2d 694 (1985) (“before any out-of-court declaration of any available living witness *683 maybe offered against a defendant in a criminal trial, the witness must be produced and declared incompetent by the court to satisfy either Article I, section 11, of the Oregon Constitution, or the Sixth Amendment to the United States Constitution”) with State v. Moen, 309 Or 45, 62 , 786 P2d 111 (1990) (citing State v. Campbell as adopting the test in Ohio v. Roberts, 448 US 56 , 100 S Ct 2531 ,65 LEd 2d 597 (1980), that “ ‘[i]n the usual case,’ the declar

11
Motes v. United Statesgreen
scotus · 1900 · cited in 1 Oregon opinions naming this issue, 1979–1979
2 sentences

1979See, e.g., Motes v. United States, 178 US 458 , 20 S Ct 993 , 44 L Ed 1150 (1900) (absence of witness no excuse where government permitted him to escape); Mattox v. United States, 156 US 237 , 15 S Ct 337 , 39 L Ed 409 (1895) (dictum); Reynolds v. United States, 98 US 145 , 25 L Ed 244 (1878) (no denial of confrontation; absence of "wife” apparently procured by defendant).

1979See, e.g., Motes v. United States, 178 US 458 , 20 S Ct 993 , 44 L Ed 1150 (1900) (absence of witness no excuse where government permitted him to escape); Mattox v. United States, 156 US 237 , 15 S Ct 337 , 39 L Ed 409 (1895) (dictum); Reynolds v. United States, 98 US 145 , 25 L Ed 244 (1878) (no denial of confrontation; absence of "wife” apparently procured by defendant).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Cookgreen
or · 2006 · cited in 1 Oregon opinions naming this issue, 2024–2024
2 sentences

2024See State v. Cook, 340 Or 530, 540 , 135 P3d 260 (2006) (explaining that, even though the United State Supreme Court no longer adheres to the test abrogated by Crawford, Oregon’s constitutional confrontation rights are governed by the earlier rule, announced in Ohio v. Roberts, 448 US 56 , 100 S Ct 2531 , 65 L Ed 2d 597 (1980), which required both witness unavailability and a firmly rooted hearsay excep- tion).

2024See State v. Cook, 340 Or 530, 540 , 135 P3d 260 (2006) (explaining that, even though the United State Supreme Court no longer adheres to the test abrogated by Crawford, Oregon’s constitutional confrontation rights are governed by the earlier rule, announced in Ohio v. Roberts, 448 US 56 , 100 S Ct 2531 , 65 L Ed 2d 597 (1980), which required both witness unavailability and a firmly rooted hearsay excep- tion).

11

Also cited on this issue (10)

CaseCitedYears
United States v. Inadi green
scotus · 1986
2 sentences

1992Id., 112 S Ct at 743 . 15 In United States v. Inadi, 475 US 387, 400 , 106 S Ct 1121 , 89 L Ed 2d 390 (1986), the Supreme Court of the United States held that the federal confrontation clause does not require that the coconspirator be unavailable for the statements of the coconspirator to be introduced.

1992Id., 112 S Ct at 743 . 15 In United States v. Inadi, 475 US 387, 400 , 106 S Ct 1121 , 89 L Ed 2d 390 (1986), the Supreme Court of the United States held that the federal confrontation clause does not require that the coconspirator be unavailable for the statements of the coconspirator to be introduced.

21992–1999
Mattox v. United States green
· 1895
2 sentences

1985After commenting that a literal reading of the federal confrontation clause would require, on objection, the exclusion of any out-of-court statement made by a declarant not available at trial, the court noted that hearsay statements have been held admissible in evidence in spite of the confrontation clause since Mattox v. United States, 156 US 237, 243 , 15 S Ct 337 , 39 L Ed 409 (1895), which approved the admission of evidence of a dying declaration.

1985After commenting that a literal reading of the federal confrontation clause would require, on objection, the exclusion of any out-of-court statement made by a declarant not available at trial, the court noted that hearsay statements have been held admissible in evidence in spite of the confrontation clause since Mattox v. United States, 156 US 237, 243 , 15 S Ct 337 , 39 L Ed 409 (1895), which approved the admission of evidence of a dying declaration.

21979–1985
People v. Johnson green
illappct · 2006
2 sentences

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

12018–2018
State v. Fields green
haw · 2007
2 sentences

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

2018Numerous courts have noted that Crawford , despite its rules restricting admission of an absent declarant's testimonial statement, "leaves no room for doubt that the federal confrontation clause is not concerned with the admission of an out-of-court statement where the declarant appears at trial and is cross-examined about that statement." State v. Fields , 115 Haw. 503 , 517, 168 P.3d 955 , 969 (2007) ; see Robinson v. State , 271 Ga. App. 584 , 587, 610 S.E.2d 194 , 197 (2005) ("Here, because the witnesses were present at trial and testified, Crawford does not apply."); see also State v. Tes

12018–2018
Crawford v. Washington green
scotus · 2004
1 sentence

2014Dept. v. Ashley, 312 Or 169, 179 , 818 P2d 1270 (1991) (relying on legislative history showing that the legislature considered including but chose not to include drug treatment records in OEC 504). 12 The state does not contend that the wife’s hearsay statements are not “witness statements” within the meaning of Article I, section 11. 13 In Crawford , the United States Supreme Court revised the federal Confrontation Clause framework, holding that testimonial evidence found “reliable” under Roberts does not necessarily satisfy the Sixth Amendment right to confrontation. 541 US at 54-56 .

12014–2014
State Ex Rel. Juvenile Department v. Ashley green
or · 1991
2 sentences

2014Dept. v. Ashley, 312 Or 169, 179 , 818 P2d 1270 (1991) (relying on legislative history showing that the legislature considered including but chose not to include drug treatment records in OEC 504). 12 The state does not contend that the wife’s hearsay statements are not “witness statements” within the meaning of Article I, section 11. 13 In Crawford , the United States Supreme Court revised the federal Confrontation Clause framework, holding that testimonial evidence found “reliable” under Roberts does not necessarily satisfy the Sixth Amendment right to confrontation. 541 US at 54-56 .

2014Dept. v. Ashley, 312 Or 169, 179 , 818 P2d 1270 (1991) (relying on legislative history showing that the legislature considered including but chose not to include drug treatment records in OEC 504). 12 The state does not contend that the wife’s hearsay statements are not “witness statements” within the meaning of Article I, section 11. 13 In Crawford , the United States Supreme Court revised the federal Confrontation Clause framework, holding that testimonial evidence found “reliable” under Roberts does not necessarily satisfy the Sixth Amendment right to confrontation. 541 US at 54-56 .

12014–2014
State v. Birchfield green
or · 2007
1 sentence

2007Id. at 632 .

12007–2007
California v. Green red
scotus · 1970
2 sentences

1999In reaching its decision, the Court did not attempt “to map out a theory of the Confrontation Clause that would determine the validity of all * * * hearsay exceptions.” Id. at 64-65 (quoting California v. Green, 399 US 149, 162 , 90 S Ct 1930 , 26 L Ed 2d 489 (1970)) (internal quotation marks omitted).

1999In reaching its decision, the Court did not attempt “to map out a theory of the Confrontation Clause that would determine the validity of all * * * hearsay exceptions.” Id. at 64-65 (quoting California v. Green, 399 US 149, 162 , 90 S Ct 1930 , 26 L Ed 2d 489 (1970)) (internal quotation marks omitted).

11999–1999
White v. Illinois green
scotus · 1992
2 sentences

1992Id., 112 S Ct at 743 . 15 In United States v. Inadi, 475 US 387, 400 , 106 S Ct 1121 , 89 L Ed 2d 390 (1986), the Supreme Court of the United States held that the federal confrontation clause does not require that the coconspirator be unavailable for the statements of the coconspirator to be introduced.

1992Id., 112 S Ct at 743 . 15 In United States v. Inadi, 475 US 387, 400 , 106 S Ct 1121 , 89 L Ed 2d 390 (1986), the Supreme Court of the United States held that the federal confrontation clause does not require that the coconspirator be unavailable for the statements of the coconspirator to be introduced.

11992–1992
Reynolds v. United States green
scotus · 1879
2 sentences

1979See, e.g., Motes v. United States, 178 US 458 , 20 S Ct 993 , 44 L Ed 1150 (1900) (absence of witness no excuse where government permitted him to escape); Mattox v. United States, 156 US 237 , 15 S Ct 337 , 39 L Ed 409 (1895) (dictum); Reynolds v. United States, 98 US 145 , 25 L Ed 244 (1878) (no denial of confrontation; absence of "wife” apparently procured by defendant).

1979See, e.g., Motes v. United States, 178 US 458 , 20 S Ct 993 , 44 L Ed 1150 (1900) (absence of witness no excuse where government permitted him to escape); Mattox v. United States, 156 US 237 , 15 S Ct 337 , 39 L Ed 409 (1895) (dictum); Reynolds v. United States, 98 US 145 , 25 L Ed 244 (1878) (no denial of confrontation; absence of "wife” apparently procured by defendant).

11979–1979

Where else courts name it

CA 26 (1980–2026) WA 22 (1993–2026) TN 10 (1989–2026) OR 8 (1979–2024) CT 6 (1987–2022) CO 5 (1998–2017) PA 4 (1994–2021) HI 3 (2007–2021) IL 2 (1977–1992) NM 2 (1999–2004) NJ 2 (1978–1989) TX 2 (1987–1993) UT 2 (1989–2009) NH 2 (1991–1999)

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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