Sixth Amendment confrontation clause (Florida) · Go Syfert
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Sixth Amendment confrontation clause in Florida

6 Florida opinions name it 3 courts 1986–2025 2 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 (4)

CaseFollowedCited
Bruton v. United Statesgreen
scotus · 1968 · cited in 2 Florida opinions naming this issue, 1990–2025
2 sentences

2025See Bruton v. United States, 391 U.S. 123, 126 (1966) (holding that a Sixth Amendment Confrontation Clause violation occurred when a non-testifying codefendant’s confession was admitted at trial).

1990In Bruton v. United States, 391 U.S. 123 , 88 S.Ct. 1620 , 20 L.Ed.2d 476 (1968), the Supreme Court held that the admission of a confession of a non-testifying code-fendant deprived a defendant of his rights under the sixth amendment confrontation clause and was so prejudicial that a limiting instruction could not cure the harm.

12
Smith v. Stategreen
fla · 2009 · cited in 1 Florida opinions naming this issue, 2022–2022
2 sentences

2022Similarly, in Smith v. State, 28 So. 3d 838, 853-55 (Fla. 2009), the Florida Supreme Court rejected an argument that the person who conducted a DNA test had to testify in order to avoid a Sixth Amendment Confrontation Clause violation.

2022There, non-testifying biologists performed the DNA test, but the state presented the testimony of “the FBI team supervisor, a forensic DNA examiner who interpreted the data, formulated the conclusions, and prepared the official report.” Id. at 853 .

11
Puiatti v. Stategreen
fla · 1988 · cited in 1 Florida opinions naming this issue, 1990–1990
1 sentence

1990An exception to this general rule was created in Parker v. Randolph, 442 U.S. 62 , 99 S.Ct. 2132 , 60 L.Ed.2d 713 (1979) in which the plurality held that a non-testifying codefendant’s confession could be admitted, with limiting instructions to the jury, where there were “interlocking” confessions, id. at 75 , 99 S.Ct. at 2140 , 60 L.Ed.2d at 725 , that is, where the “ ‘salient facts against the first defendant that appear in the confession of the second defendant also appear in the confession of the first, and vice versa.’ ” Puiatti v. State, 521 So.2d 1106, 1107 (Fla.1988) (citation omitted)

11
California v. Greenred
scotus · 1970 · cited in 1 Florida opinions naming this issue, 1988–1988
2 sentences

1988See California v. Green, 399 U.S. 149 , 90 S.Ct. 1930 , 26 L.Ed.2d 489 (1970).

1988See California v. Green, 399 U.S. 149 , 90 S.Ct. 1930 , 26 L.Ed.2d 489 (1970).

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 (7)

CaseCitedYears
Parker v. Randolph red
scotus · 1979
2 sentences

1990An exception to this general rule was created in Parker v. Randolph, 442 U.S. 62 , 99 S.Ct. 2132 , 60 L.Ed.2d 713 (1979) in which the plurality held that a non-testifying codefendant’s confession could be admitted, with limiting instructions to the jury, where there were “interlocking” confessions, id. at 75 , 99 S.Ct. at 2140 , 60 L.Ed.2d at 725 , that is, where the “ ‘salient facts against the first defendant that appear in the confession of the second defendant also appear in the confession of the first, and vice versa.’ ” Puiatti v. State, 521 So.2d 1106, 1107 (Fla.1988) (citation omitted)

1990An exception to this general rule was created in Parker v. Randolph, 442 U.S. 62 , 99 S.Ct. 2132 , 60 L.Ed.2d 713 (1979) in which the plurality held that a non-testifying codefendant’s confession could be admitted, with limiting instructions to the jury, where there were “interlocking” confessions, id. at 75 , 99 S.Ct. at 2140 , 60 L.Ed.2d at 725 , that is, where the “ ‘salient facts against the first defendant that appear in the confession of the second defendant also appear in the confession of the first, and vice versa.’ ” Puiatti v. State, 521 So.2d 1106, 1107 (Fla.1988) (citation omitted)

11990–1990
Pointer v. Texas green
scotus · 1965
2 sentences

1989Pointer v Texas, 380 U.S. 400 , 85 S.Ct. 1065 (1968).

1989Pointer v Texas, 380 U.S. 400 , 85 S.Ct. 1065 (1968).

11989–1989
Schneble v. Florida green
scotus · 1972
2 sentences

1986Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972); Hall v. State, 381 So.2d 683 (Fla. 1978); Broome v. State, 194 So.2d 31 (Fla. 2d DCA 1967); Seely v. State, 191 So.2d 78 (Fla. 2d DCA 1966), cert. denied, 196 So.2d 925 (Fla. 1967).

1986Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972); Hall v. State, 381 So.2d 683 (Fla. 1978); Broome v. State, 194 So.2d 31 (Fla. 2d DCA 1967); Seely v. State, 191 So.2d 78 (Fla. 2d DCA 1966), cert. denied, 196 So.2d 925 (Fla. 1967).

11986–1986
Hall v. State green
fla · 1979
1 sentence

1986Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972); Hall v. State, 381 So.2d 683 (Fla. 1978); Broome v. State, 194 So.2d 31 (Fla. 2d DCA 1967); Seely v. State, 191 So.2d 78 (Fla. 2d DCA 1966), cert. denied, 196 So.2d 925 (Fla. 1967).

11986–1986
Seely v. State neutral
fladistctapp · 1966
1 sentence

1986Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972); Hall v. State, 381 So.2d 683 (Fla. 1978); Broome v. State, 194 So.2d 31 (Fla. 2d DCA 1967); Seely v. State, 191 So.2d 78 (Fla. 2d DCA 1966), cert. denied, 196 So.2d 925 (Fla. 1967).

11986–1986
Broome v. State neutral
fladistctapp · 1967
1 sentence

1986Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972); Hall v. State, 381 So.2d 683 (Fla. 1978); Broome v. State, 194 So.2d 31 (Fla. 2d DCA 1967); Seely v. State, 191 So.2d 78 (Fla. 2d DCA 1966), cert. denied, 196 So.2d 925 (Fla. 1967).

11986–1986
Nicholls v. Nicholls green
fla · 1967
1 sentence

1986Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972); Hall v. State, 381 So.2d 683 (Fla. 1978); Broome v. State, 194 So.2d 31 (Fla. 2d DCA 1967); Seely v. State, 191 So.2d 78 (Fla. 2d DCA 1966), cert. denied, 196 So.2d 925 (Fla. 1967).

11986–1986

Where else courts name it

CA 46 (1998–2026) IL 35 (1987–2026) WA 20 (1987–2021) TX 16 (1973–2025) FL 6 (1986–2025) HI 6 (1994–2010) DC 5 (1983–2009) NJ 4 (1991–2004) WY 4 (1993–2017) MI 4 (1980–1982) IN 4 (1989–2025) CT 4 (1986–2010) WI 4 (1987–2022) NM 3 (1976–2013) AZ 3 (1976–1988) VA 3 (1991–2015) MN 3 (1986–1990) PA 3 (1981–2001) MO 3 (1996–2014) SD 2 (1980–2000) NY 2 (1979–1983) OH 2 (2003–2012) MS 2 (1993–2001) MA 2 (2008–2009) LA 2 (1990–2006) ID 2 (2002–2011) NC 2 (1988–2006) ME 2 (1979–2022) RI 2 (1987–2004) KS 2 (1989–1993)

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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