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6 District of Columbia opinions name it 1 courts 1996–2009 0 in the last five years
The cases below were cited by District of Columbia 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.
| Case | Followed | Cited |
|---|---|---|
Ohio v. Robertsred2 sentences2005Prior to Crawford, and under the regime of Roberts , any out-of-court statement was constitutionally admissible so long as it either fell within a firmly rooted exception to the hearsay rule or bore “particularized guarantees of trustworthiness.” Id. at 1369 (quoting Roberts, 448 U.S. at 66 , 100 S.Ct. 2531 ). 2005Prior to Crawford, and under the regime of Roberts , any out-of-court statement was constitutionally admissible so long as it either fell within a firmly rooted exception to the hearsay rule or bore “particularized guarantees of trustworthiness.” Id. at 1369 (quoting Roberts, 448 U.S. at 66 , 100 S.Ct. 2531 ). | 1 | 2 |
Akins v. United Statesgreen2 sentences2005See Akins, supra, 679 A.2d at 1030 . 2005See Akins, supra, 679 A.2d at 1030 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Brown v. Keanegreen2 sentences2004But see Brown v. Keane, 229 F.Supp.2d 298, 304-10 (S.D.N.Y.2002) (reviewing cases and concluding, “albeit not without hesitation,” that present sense impression exception is firmly rooted). 2004But see Brown v. Keane, 229 F.Supp.2d 298, 304-10 (S.D.N.Y.2002) (reviewing cases and concluding, "albeit not without hesitation," that present sense impression exception is firmly rooted). | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
White v. Illinois
green
2 sentences1996Furthermore, since the statements of Ms. Gibson had “sufficient guarantees of reliability to come within a firmly rooted exception to the hearsay rule,” i.e., the excited utterance exception, the confrontation clause of the Sixth Amendment “is satisfied.” White v. Illinois, 502 U.S. 346 , 112 S.Ct. 736 , 116 L.Ed.2d 848 (1992). 1996Furthermore, since the statements of Ms. Gibson had “sufficient guarantees of reliability to come within a firmly rooted exception to the hearsay rule,” i.e., the excited utterance exception, the confrontation clause of the Sixth Amendment “is satisfied.” White v. Illinois, 502 U.S. 346 , 112 S.Ct. 736 , 116 L.Ed.2d 848 (1992). | 2 | 1996–2009 |
United States v. James Saget, Also Known as Hesh
green
1 sentence2005The change effected by Crawford was concisely summarized in United States v. Saget, 377 F.3d 223 (2d Cir.2004): Crawford abrogates Roberts with respect to prior testimonial statements by holding that such statements may never be introduced against the defendant unless he or she had an opportunity to *806 cross-examine the declarant, regardless of whether that statement falls within a firmly rooted hearsay exception or has particularized guarantees of trustworthiness. | 1 | 2005–2005 |
Lilly v. Virginia
green
1 sentence2000The other two categories of statements against penal interest, specified in Lilly, supra, are those offered "(1) as voluntary admissions against the declarant; [and] (2) exculpatory evidence offered by a defendant who claims that the declarant committed, or was involved in, the offense.” Id. at 127 , 119 S.Ct. 1887 . 17 . | 1 | 2000–2000 |
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.
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.