may predicate error (Florida) · Go Syfert
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may predicate error in Florida

7 Florida opinions name it 2 courts 1986–2014 0 in the last five years

The cases below were cited by Florida 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 (6)

CaseFollowedCited
Jacobs v. Wainwrightgreen
fla · 1984 · cited in 2 Florida opinions naming this issue, 1986–2013
2 sentences

2013See 90.104(l)(b), Fla. Stat. (2009) (“A court may predicate error, set aside or reverse a judgment, or grant a new trial on the basis of admitted or excluded evidence when a substantial right of the party is adversely affected and [w]hen the ruling is one excluding evidence, the substance of the evidence was made known to the court by offer of proof or was apparent from the context within which the questions were asked.”); see generally Blackwood v. State, 777 So.2d 399, 410-11 (Fla.2000) (“In order to preserve a claim based on the court’s refusal to admit evidence, the party seeking to admit

1986See also Woodson v. State, 483 So.2d 858 (Fla. 5th DCA 1986); Nava v. State, 450 So.2d 606 (Fla. 4th DCA 1984); Jacobs v. Wainwright, 450 So.2d 200 (Fla.1984); Ehrhardt, Florida Evidence § 104.3 (2d Ed. 1984).

12
Lynch v. McGoverngreen
fladistctapp · 1972 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014In Lynch v. McGovern, 270 So.2d 770, 772 (Fla. 4th DCA 1972) (quoting Wigmore on Evidence, Vol. 2 (3d ed.), section 278, at 120), the Fourth District stated: * * * it has always been understood — the inference, indeed, is one of the simplest in human experience — that a party’s falsehood or other fraud in the preparation and presentation of his cause, his fabrication or suppression of evidence by bribery or spoliation, and all similar conduct, is receivable against him as an indication of his consciousness that his case is a weak or unfounded one; and from that consciousness may be inferred th

11
Blackwood v. Stategreen
fla · 2000 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013See 90.104(l)(b), Fla. Stat. (2009) (“A court may predicate error, set aside or reverse a judgment, or grant a new trial on the basis of admitted or excluded evidence when a substantial right of the party is adversely affected and [w]hen the ruling is one excluding evidence, the substance of the evidence was made known to the court by offer of proof or was apparent from the context within which the questions were asked.”); see generally Blackwood v. State, 777 So.2d 399, 410-11 (Fla.2000) (“In order to preserve a claim based on the court’s refusal to admit evidence, the party seeking to admit

11
Lucas v. Stategreen
fla · 1990 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013See 90.104(l)(b), Fla. Stat. (2009) (“A court may predicate error, set aside or reverse a judgment, or grant a new trial on the basis of admitted or excluded evidence when a substantial right of the party is adversely affected and [w]hen the ruling is one excluding evidence, the substance of the evidence was made known to the court by offer of proof or was apparent from the context within which the questions were asked.”); see generally Blackwood v. State, 777 So.2d 399, 410-11 (Fla.2000) (“In order to preserve a claim based on the court’s refusal to admit evidence, the party seeking to admit

11
O'Shea v. O'Sheagreen
fladistctapp · 1991 · cited in 1 Florida opinions naming this issue, 1994–1994
1 sentence

1994See also O'Shea v. O'Shea, 585 So.2d 405, 407 (Fla. 1st DCA 1991).

11
Woodson v. Stategreen
fladistctapp · 1986 · cited in 1 Florida opinions naming this issue, 1986–1986
1 sentence

1986See also Woodson v. State, 483 So.2d 858 (Fla. 5th DCA 1986); Nava v. State, 450 So.2d 606 (Fla. 4th DCA 1984); Jacobs v. Wainwright, 450 So.2d 200 (Fla.1984); Ehrhardt, Florida Evidence § 104.3 (2d Ed. 1984).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Seeba v. Bowden green
fla · 1956
2 sentences

1995Dr. Key points to Seeba v. Bowden, 86 So.2d 432 (Fla. 1956), in which this Court stated that it was unnecessary to make a proffer of excluded testimony in order to preserve error where the testimony is excluded on the basis that the witness is incompetent.

1991However, section 90.104(1)(b), Florida Statutes, provides: (1) A court may predicate error, set aside or reverse a judgment, or grant a new trial on the basis of admitted or excluded evidence when a substantial right of the party is adversely affected and: (b) When the ruling is one excluding evidence, the substance of the evidence was made known to the court by offer of proof or was apparent from the context within which the questions were asked. (e.s.) In Seeba v. Bowen, 86 So.2d 432 (Fla. 1956), Justice O'Connell wrote that a proffer is unnecessary "where the offer would be a useless ceremo

21991–1995
A. McD. v. State green
fladistctapp · 1982
1 sentence

1990"It is axiomatic that failure to proffer what the excluded evidence would have revealed precludes appellate consideration of the alleged error." A.McD. v. State, 422 So.2d 336 , 337 Fla. 3d DCA 1982) (citations omitted).

11990–1990
Nava v. State green
fladistctapp · 1984
1 sentence

1986See also Woodson v. State, 483 So.2d 858 (Fla. 5th DCA 1986); Nava v. State, 450 So.2d 606 (Fla. 4th DCA 1984); Jacobs v. Wainwright, 450 So.2d 200 (Fla.1984); Ehrhardt, Florida Evidence § 104.3 (2d Ed. 1984).

11986–1986

Statutes the citing opinions construe

FL § 90.104 (6)

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.

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