firmly rooted exception (Tennessee) · Go Syfert
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firmly rooted exception in Tennessee

7 Tennessee opinions name it 2 courts 2002–2010 0 in the last five years

The cases below were cited by Tennessee 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 (3)

CaseFollowedCited
White v. Illinoisgreen
scotus · 1992 · cited in 2 Tennessee opinions naming this issue, 2004–2010
2 sentences

2010Later, however, the Supreme Court ruled that "where the proffered hearsay has sufficient guarantees of reliability to come within a firmly rooted exception to the hearsay rule, the Confrontation Clause is satisfied." White v. Illinois, 502 U.S. 346, 356 (1992). 22 In Henderson, 554 S.W.2d at 119-20 , our supreme court ruled that toxicology reports indicating the presence of illegal drugs could not be admitted through a witness other than the one that performed the test.

2004The Supreme Court has held, however, that the confrontation clause is satisfied by evidence that falls “within a firmly rooted exception to the hearsay rule[.]” White v. Illinois, 502 U.S. 346, 356 , 112 S. Ct. 736, 743 , 116 L.

12
Stevens v. Peoplegreen
colo · 2001 · cited in 1 Tennessee opinions naming this issue, 2004–2004
1 sentence

2004A "statement against interest by a co- defendant made during custodial interrogation does not fall within a firmly rooted hearsay exception." Farrell, 34 P.3d at 406 (quoting Stevens v. People, 29 P.3d 305, 313 (Colo. 2001.)) Because Guartos is a co-defendant, who made statements against interest in the course of a custodial interrogation, his statements cannot be classified as falling under a firmly rooted exception to the hearsay rule.

11
Lilly v. Virginiagreen
scotus · 1999 · cited in 1 Tennessee opinions naming this issue, 2002–2002
2 sentences

2002That having been said, the plurality in Lilly v. Virginia, 527 U.S. 116, 133-134 , 119 S. Ct. 1887, 1898-1899 (1999), declined to hold that, in the specific context of accomplices’ confessions that inculpate a criminal defendant, the statement against interest exception -48- to the hearsay rule is a firmly rooted exception for purposes of the Confrontation Clause of the Sixth Amendment to the United States Constitution, albeit the government may demonstrate that a confession possesses particularized guarantees of trustworthiness dispensing with the need for confrontation.

2002That having been said, the plurality in Lilly v. Virginia, 527 U.S. 116, 133-134 , 119 S. Ct. 1887, 1898-1899 (1999), declined to hold that, in the specific context of accomplices’ confessions that inculpate a criminal defendant, the statement against interest exception -48- to the hearsay rule is a firmly rooted exception for purposes of the Confrontation Clause of the Sixth Amendment to the United States Constitution, albeit the government may demonstrate that a confession possesses particularized guarantees of trustworthiness dispensing with the need for confrontation.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Crawford v. Washington green
scotus · 2004
2 sentences

2007In Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 (2004), however, the Supreme Court departed from its ruling in RobeHs and established a new standard for the admissibility of hearsay statements under the Confrontation Clause. 2 Id. at 61 .

2007In Crawford v. Washington, 541 U.S. 36 , 124 S.Ct. 1354 , 158 L.Ed.2d 177 (2004), however, the Supreme Court departed from its ruling in RobeHs and established a new standard for the admissibility of hearsay statements under the Confrontation Clause. 2 Id. at 61 .

32006–2007
Ohio v. Roberts red
scotus · 1980
2 sentences

2007In Roberts , the Court held that “when a hearsay declarant is not present for cross-examination at trial, the Confrontation Clause normally requires a showing that he is unavailable,” id. at 66 , and even when there is a showing of unavailability, the hearsay statement “is admissible only if it bears adequate ‘indicia of reliability,’ ” id. “[Ujnder Roberts , an out-of-court statement by an unavailable witness is admissible if it (1) falls within a firmly rooted exception to the hearsay rule or (2) contains such particularized guarantees of trustworthiness that adversarial testing of the state

2007In Roberts , the Court held that “when a hearsay declarant is not present for cross-examination at trial, the Confrontation Clause normally requires a showing that he is unavailable,” id. at 66 , and even when there is a showing of unavailability, the hearsay statement “is admissible only if it bears adequate ‘indicia of reliability,’ ” id. “[Ujnder Roberts , an out-of-court statement by an unavailable witness is admissible if it (1) falls within a firmly rooted exception to the hearsay rule or (2) contains such particularized guarantees of trustworthiness that adversarial testing of the state

32006–2007
State v. Henderson green
tenn · 1977
1 sentence

2010Later, however, the Supreme Court ruled that "where the proffered hearsay has sufficient guarantees of reliability to come within a firmly rooted exception to the hearsay rule, the Confrontation Clause is satisfied." White v. Illinois, 502 U.S. 346, 356 (1992). 22 In Henderson, 554 S.W.2d at 119-20 , our supreme court ruled that toxicology reports indicating the presence of illegal drugs could not be admitted through a witness other than the one that performed the test.

12010–2010
State v. MacLin red
tenn · 2006
1 sentence

2007In Roberts , the Court held that “when a hearsay declarant is not present for cross-examination at trial, the Confrontation Clause normally requires a showing that he is unavailable,” id. at 66 , and even when there is a showing of unavailability, the hearsay statement “is admissible only if it bears adequate ‘indicia of reliability,’ ” id. “[Ujnder Roberts , an out-of-court statement by an unavailable witness is admissible if it (1) falls within a firmly rooted exception to the hearsay rule or (2) contains such particularized guarantees of trustworthiness that adversarial testing of the state

12007–2007
People v. Farrell green
colo · 2001
1 sentence

2004A "statement against interest by a co- defendant made during custodial interrogation does not fall within a firmly rooted hearsay exception." Farrell, 34 P.3d at 406 (quoting Stevens v. People, 29 P.3d 305, 313 (Colo. 2001.)) Because Guartos is a co-defendant, who made statements against interest in the course of a custodial interrogation, his statements cannot be classified as falling under a firmly rooted exception to the hearsay rule.

12004–2004

Where else courts name it

TX 47 (1987–2017) OH 30 (1992–2012) CA 22 (1993–2023) VA 21 (1996–2020) IL 20 (1989–2024) NM 17 (1996–2017) WA 17 (1998–2009) CO 17 (1993–2026) PA 15 (1990–2026) NC 14 (1994–2009) LA 12 (1995–2017) AL 12 (1994–2026) FL 11 (1988–2019) MO 11 (1898–2007) MN 10 (1991–2006) AZ 10 (1990–2003) GA 9 (1995–2011) MD 9 (1988–2016) CT 8 (1992–2010) MA 7 (1994–2025) WY 7 (1997–2022) TN 7 (2002–2010) DE 7 (1998–2017) SC 7 (1995–2006) IN 7 (1994–2010) WI 6 (1982–2002) MI 6 (1991–2020) DC 6 (1996–2009) KY 6 (2001–2006) OK 5 (1996–2014) IA 4 (1994–2005) SD 4 (1986–2000) MT 3 (2001–2006) WV 3 (1999–2003) HI 3 (1992–2018) ME 2 (1995–2003) ID 2 (1999–2001) MS 2 (2000–2004) OR 2 (1993–2000) KS 2 (2001–2005) NE 2 (1993–2000) AK 2 (1994–1994)

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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