public records exception (Idaho) · Go Syfert
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public records exception in Idaho

6 Idaho opinions name it 2 courts 1990–2026 1 in the last five years

The cases below were cited by Idaho 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 (10)

CaseFollowedCited
State v. Sandoval-Tenagreen
idaho · 2003 · cited in 2 Idaho opinions naming this issue, 2019–2026
2 sentences

2026See Fragnella v. Petrovich, 153 Idaho 266, 275 , 281 P.3d 103, 112 (2012) (holding that a police report was inadmissible under the catch-all exception to hearsay); State v. Sandoval-Tena, 138 Idaho 908, 912 , 71 P.3d 1055, 1059 (2003) (holding that a police report is inadmissible under both the public records exception and the business records exception to the hearsay rule).

2026See Fragnella v. Petrovich, 153 Idaho 266, 275 , 281 P.3d 103, 112 (2012) (holding that a police report was inadmissible under the catch-all exception to hearsay); State v. Sandoval-Tena, 138 Idaho 908, 912 , 71 P.3d 1055, 1059 (2003) (holding that a police report is inadmissible under both the public records exception and the business records exception to the hearsay rule).

12
Tiffany Ann Marie Fragnella v. Robert B. Petrovich, Jr.green
idaho · 2012 · cited in 1 Idaho opinions naming this issue, 2026–2026
2 sentences

2026See Fragnella v. Petrovich, 153 Idaho 266, 275 , 281 P.3d 103, 112 (2012) (holding that a police report was inadmissible under the catch-all exception to hearsay); State v. Sandoval-Tena, 138 Idaho 908, 912 , 71 P.3d 1055, 1059 (2003) (holding that a police report is inadmissible under both the public records exception and the business records exception to the hearsay rule).

2026See Fragnella v. Petrovich, 153 Idaho 266, 275 , 281 P.3d 103, 112 (2012) (holding that a police report was inadmissible under the catch-all exception to hearsay); State v. Sandoval-Tena, 138 Idaho 908, 912 , 71 P.3d 1055, 1059 (2003) (holding that a police report is inadmissible under both the public records exception and the business records exception to the hearsay rule).

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Martinez v. Carreterogreen
idaho · 2023 · cited in 1 Idaho opinions naming this issue, 2026–2026
2 sentences

2026Johnson further argues that the OSHA citation and cover letter were admissible under the business records exception or the public records exception “[b]ecause OSHA records constitute factual findings from a legally authorized investigation by a public office.” In response, Beadz Brothers argues that Exhibit 17 failed to raise any genuine issue 10 of material fact because the letter only “explain[ed] the known facts about the accident in which [Colby] was involved . . . .” For the reasons set forth below, we conclude that any error of the district court in striking Exhibit 17 was harmless error

2026Johnson further argues that the OSHA citation and cover letter were admissible under the business records exception or the public records exception “[b]ecause OSHA records constitute factual findings from a legally authorized investigation by a public office.” In response, Beadz Brothers argues that Exhibit 17 failed to raise any genuine issue 10 of material fact because the letter only “explain[ed] the known facts about the accident in which [Colby] was involved . . . .” For the reasons set forth below, we conclude that any error of the district court in striking Exhibit 17 was harmless error

11
Chelsea Reed v. Zane Reedgreen
idaho · 2016 · cited in 1 Idaho opinions naming this issue, 2026–2026
2 sentences

2026Johnson further argues that the OSHA citation and cover letter were admissible under the business records exception or the public records exception “[b]ecause OSHA records constitute factual findings from a legally authorized investigation by a public office.” In response, Beadz Brothers argues that Exhibit 17 failed to raise any genuine issue 10 of material fact because the letter only “explain[ed] the known facts about the accident in which [Colby] was involved . . . .” For the reasons set forth below, we conclude that any error of the district court in striking Exhibit 17 was harmless error

2026Johnson further argues that the OSHA citation and cover letter were admissible under the business records exception or the public records exception “[b]ecause OSHA records constitute factual findings from a legally authorized investigation by a public office.” In response, Beadz Brothers argues that Exhibit 17 failed to raise any genuine issue 10 of material fact because the letter only “explain[ed] the known facts about the accident in which [Colby] was involved . . . .” For the reasons set forth below, we conclude that any error of the district court in striking Exhibit 17 was harmless error

11
Navarro v. Yonkersgreen
idaho · 2007 · cited in 1 Idaho opinions naming this issue, 2020–2020
2 sentences

2020The “Idaho Rules of Evidence allow for the admission of public records as an exception to the hearsay rule.” Navarro v. Yonkers, 144 Idaho 882, 886 , 173 P.3d 1141, 1145 (2007) (citing I.R.E. 803(8)).

2020The “Idaho Rules of Evidence allow for the admission of public records as an exception to the hearsay rule.” Navarro v. Yonkers, 144 Idaho 882, 886 , 173 P.3d 1141, 1145 (2007) (citing I.R.E. 803(8)).

11
United States v. Paul v. Oatesgreen
ca2 · 1977 · cited in 1 Idaho opinions naming this issue, 2003–2003
2 sentences

2003In United States v. Oates, 560 F.2d 45, 68 (2d Cir.1977), the court found that a report such as this one is inadmissible under a similar public records exception.

2003In United States v. Oates, 560 F.2d 45, 68 (2d Cir.1977), the court found that a report such as this one is inadmissible under a similar public records exception.

11
State v. Bertulgreen
utah · 1983 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996See United States v. De Peri, 778 F.2d 963, 976-77 (3d Cir.1985) (An FBI report would be admissible against the government under the public records exception.); United States v. Smith, 521 F.2d 957, 967-68 (D.C.Cir.1975) (Police reports offered by defendant as business records were admissible against the prosecution.); State v. Bertul, 664 P.2d 1181, 1185 (Utah 1983) (A police report is ordinarily admissible under the business records exception when offered by the defendant in a criminal case to support his or her defense.).

1996See United States v. De Peri, 778 F.2d 963, 976-77 (3d Cir.1985) (An FBI report would be admissible against the government under the public records exception.); United States v. Smith, 521 F.2d 957, 967-68 (D.C.Cir.1975) (Police reports offered by defendant as business records were admissible against the prosecution.); State v. Bertul, 664 P.2d 1181, 1185 (Utah 1983) (A police report is ordinarily admissible under the business records exception when offered by the defendant in a criminal case to support his or her defense.).

11
cluster 461592green
ca3 · 1986 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996See United States v. De Peri, 778 F.2d 963, 976-77 (3d Cir.1985) (An FBI report would be admissible against the government under the public records exception.); United States v. Smith, 521 F.2d 957, 967-68 (D.C.Cir.1975) (Police reports offered by defendant as business records were admissible against the prosecution.); State v. Bertul, 664 P.2d 1181, 1185 (Utah 1983) (A police report is ordinarily admissible under the business records exception when offered by the defendant in a criminal case to support his or her defense.).

1996See United States v. De Peri, 778 F.2d 963, 976-77 (3d Cir.1985) (An FBI report would be admissible against the government under the public records exception.); United States v. Smith, 521 F.2d 957, 967-68 (D.C.Cir.1975) (Police reports offered by defendant as business records were admissible against the prosecution.); State v. Bertul, 664 P.2d 1181, 1185 (Utah 1983) (A police report is ordinarily admissible under the business records exception when offered by the defendant in a criminal case to support his or her defense.).

11
United States v. Joseph E. Smithgreen
cadc · 1975 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996See United States v. De Peri, 778 F.2d 963, 976-77 (3d Cir.1985) (An FBI report would be admissible against the government under the public records exception.); United States v. Smith, 521 F.2d 957, 967-68 (D.C.Cir.1975) (Police reports offered by defendant as business records were admissible against the prosecution.); State v. Bertul, 664 P.2d 1181, 1185 (Utah 1983) (A police report is ordinarily admissible under the business records exception when offered by the defendant in a criminal case to support his or her defense.).

1996See United States v. De Peri, 778 F.2d 963, 976-77 (3d Cir.1985) (An FBI report would be admissible against the government under the public records exception.); United States v. Smith, 521 F.2d 957, 967-68 (D.C.Cir.1975) (Police reports offered by defendant as business records were admissible against the prosecution.); State v. Bertul, 664 P.2d 1181, 1185 (Utah 1983) (A police report is ordinarily admissible under the business records exception when offered by the defendant in a criminal case to support his or her defense.).

11
State v. Gomezgreen
idahoctapp · 1994 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996Hearsay is defined as “a statement, other than one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the matter asserted.” I.R.E. 801(c); State v. Gomez, 126 Idaho 700, 704 , 889 P.2d 729, 738 (Ct.App.1994).

1996Hearsay is defined as “a statement, other than one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the matter asserted.” I.R.E. 801(c); State v. Gomez, 126 Idaho 700, 704 , 889 P.2d 729, 738 (Ct.App.1994).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Kehm v. Procter & Gamble Manufacturing Company green
ca8 · 1983
2 sentences

1990Co., 724 F.2d 613 (8th Cir.1983).

1990Co., 724 F.2d 613 (8th Cir.1983).

11990–1990
Jefferey Dale Ellis, Administrator of the Estate of Margaret Ann Ellis, Deceased v. International Playtex, Inc., a Delaware Corporation green
ca4 · 1984
2 sentences

1990Numerous cases have held that CDC data is admissible under the public records exception, see, e.g., Ellis v. International Playtex, Inc., 745 F.2d 292 (4th Cir.1984), and Kehm v. Proctor & Gamble Mfg.

1990Numerous cases have held that CDC data is admissible under the public records exception, see, e.g., Ellis v. International Playtex, Inc., 745 F.2d 292 (4th Cir.1984), and Kehm v. Proctor & Gamble Mfg.

11990–1990

Statutes the citing opinions construe

ID § Idaho Code § 12-121 (3)

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.

Where else courts name it

LA 119 (1957–2025) OH 65 (1991–2026) TX 43 (1983–2026) FL 42 (1971–2025) IN 21 (1982–2024) CA 20 (1994–2026) WA 18 (1984–2026) PA 18 (1971–2025) IL 16 (1978–2024) NM 15 (1995–2020) MI 11 (1992–2025) AZ 11 (1989–2022) WI 10 (1998–2025) NJ 10 (2002–2024) MA 8 (1985–2025) AK 8 (1988–2025) DC 7 (1991–2009) MD 7 (1990–2018) TN 6 (1999–2018) NC 6 (2006–2026) ID 6 (1990–2026) OR 6 (1992–2025) HI 5 (1996–2019) ME 5 (1984–2022) NV 5 (2014–2017) GA 5 (1998–2016) MS 4 (2003–2021) IA 4 (1982–2025) SD 4 (2004–2026) OK 4 (1936–2014) CO 4 (1987–2015) VA 3 (2003–2019) SC 3 (2008–2014) NY 3 (2007–2010) CT 2 (1970–1997) UT 2 (1987–2017) AL 2 (2000–2000) VT 2 (2000–2026) NE 2 (1938–2013) ND 2 (2009–2013) WV 2 (1999–2002) MN 2 (1984–2024) DE 2 (1986–2001)

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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