presence requirement (North Dakota) · Go Syfert
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presence requirement in North Dakota

6 North Dakota opinions name it 1 courts 1971–2023 1 in the last five years

The cases below were cited by North Dakota 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 (9)

CaseFollowedCited
United States v. Alessandrello, Gaetano, in No. 79-2654. Appeal of Lacognata, Salvatore, in No. 79-2699green
ca3 · 1980 · cited in 2 North Dakota opinions naming this issue, 1998–2023
2 sentences

2023United States v. Alessandrello, 637 F.2d 131, 138 (3d Cir. 1980), cert. denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it ‘embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence’).

1998United States v. AUssandrel-lo, 637 F.2d 131, 138 (3d Cir.1980), cert, denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it “embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence”).

22
Matter of Estate of Stantongreen
nd · 1991 · cited in 1 North Dakota opinions naming this issue, 2019–2019
1 sentence

2019This Court has stated, “Recitals in an attestation clause of a will are presumed to be true and can be used to establish due execution unless the presumption of truth is overcome by clear and convincing evidence.” Estate of Wagner, 551 N.W.2d 292, 295 (N.D. 1996) (quoting Estate of Stanton, 472 N.W.2d 741, 744 (N.D. 1991)). [¶11] The Jensens’ argument on the validity of Blikre’s will is based on Jean Nordahl’s November 2018 deposition testimony about the circumstances surrounding the execution of the will.

11
Matter of Estate of Wagnergreen
nd · 1996 · cited in 1 North Dakota opinions naming this issue, 2019–2019
1 sentence

2019This Court has stated, “Recitals in an attestation clause of a will are presumed to be true and can be used to establish due execution unless the presumption of truth is overcome by clear and convincing evidence.” Estate of Wagner, 551 N.W.2d 292, 295 (N.D. 1996) (quoting Estate of Stanton, 472 N.W.2d 741, 744 (N.D. 1991)). [¶11] The Jensens’ argument on the validity of Blikre’s will is based on Jean Nordahl’s November 2018 deposition testimony about the circumstances surrounding the execution of the will.

11
United States v. German Severinogreen
ca2 · 1986 · cited in 1 North Dakota opinions naming this issue, 2001–2001
1 sentence

2001United States v. Severino, 800 F.2d 42, 47-48 (2nd Cir.1986); see also United States v. Ploof, 464 F.2d 116, 118 (2nd Cir.1972) (the trial judge had discretion to require counsel to exercise challenges in the presence and hearing of veniremen rather than at side bar); United States v. Rowe, 435 F.2d 1298, 1299 (9th Cir.1970) (the court’s ruling on peremptory challenge of a juror in front of the jury offended no statute or rule of procedure-for exercising peremptory challenges).

11
United States v. William Washabaugh, Jr., William David Wentroblegreen
ca9 · 1970 · cited in 1 North Dakota opinions naming this issue, 2001–2001
1 sentence

2001United States v. Severino, 800 F.2d 42, 47-48 (2nd Cir.1986); see also United States v. Ploof, 464 F.2d 116, 118 (2nd Cir.1972) (the trial judge had discretion to require counsel to exercise challenges in the presence and hearing of veniremen rather than at side bar); United States v. Rowe, 435 F.2d 1298, 1299 (9th Cir.1970) (the court’s ruling on peremptory challenge of a juror in front of the jury offended no statute or rule of procedure-for exercising peremptory challenges).

11
United States v. Roger R. Ploof and George J. Godingreen
ca2 · 1972 · cited in 1 North Dakota opinions naming this issue, 2001–2001
1 sentence

2001United States v. Severino, 800 F.2d 42, 47-48 (2nd Cir.1986); see also United States v. Ploof, 464 F.2d 116, 118 (2nd Cir.1972) (the trial judge had discretion to require counsel to exercise challenges in the presence and hearing of veniremen rather than at side bar); United States v. Rowe, 435 F.2d 1298, 1299 (9th Cir.1970) (the court’s ruling on peremptory challenge of a juror in front of the jury offended no statute or rule of procedure-for exercising peremptory challenges).

11
Campbell v. Woodgreen
ca9 · 1994 · cited in 1 North Dakota opinions naming this issue, 1998–1998
1 sentence

1998In Campbell v. Wood, 18 F.3d 662, 671 (9th Cir. 1994), cert, denied, 511 U.S. 1119 , 114 S.Ct. 2125 , 128 L.Ed.2d 682 (1994), the Ninth Circuit outlined the change: "In Diaz v. United States, 223 U.S. 442, 455 , 32 S.Ct. 250, 254 , 56 L.Ed. 500 (1912), the Court distinguished between capital and noncapital cases and between custodial and noncustodial defendants, stating that the courts have regarded an accused who is in custody and one who is charged with a capital offense as incapable of waiving the right; the one, because his presence or absence is not within his own control, and the other b

11
Donald David Jones v. United Statesgreen
ca10 · 1962 · cited in 1 North Dakota opinions naming this issue, 1998–1998
1 sentence

1998Jones v. United States, 299 F.2d 661, 662 (10th Cir.1962).

11
United States v. James McCoygreen
cadc · 1970 · cited in 1 North Dakota opinions naming this issue, 1971–1971
2 sentences

1971The U. S. Court of Appeals for the District of Columbia subsequently held that “the Sixth Amendment requires the presence of defense counsel and the accused at all critical stages of the prosecution.” United States v. McCoy, 139 U.S.App.D.C. 60 , 429 F.2d 739, 742 (1970).

1971The U. S. Court of Appeals for the District of Columbia subsequently held that “the Sixth Amendment requires the presence of defense counsel and the accused at all critical stages of the prosecution.” United States v. McCoy, 139 U.S.App.D.C. 60 , 429 F.2d 739, 742 (1970).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (11)

CaseCitedYears
Illinois v. Allen green
scotus · 1970
2 sentences

2023Illinois v. Allen, 397 U.S. 337, 338 , 90 S.Ct. 1057, 1058 , 25 L.Ed.2d 353 , reh’g denied, 398 U.S. 1 915 , 90 S.Ct. 1684 , 26 L.Ed.2d 80 (1970).

2023Illinois v. Allen, 397 U.S. 337, 338 , 90 S.Ct. 1057, 1058 , 25 L.Ed.2d 353 , reh’g denied, 398 U.S. 1 915 , 90 S.Ct. 1684 , 26 L.Ed.2d 80 (1970).

21998–2023
Byrne v. P. B. I. C., Inc. green
scotus · 1970
2 sentences

2023Illinois v. Allen, 397 U.S. 337, 338 , 90 S.Ct. 1057, 1058 , 25 L.Ed.2d 353 , reh’g denied, 398 U.S. 1 915 , 90 S.Ct. 1684 , 26 L.Ed.2d 80 (1970).

1998Illinois v. Allen, 397 U.S. 337, 338 , 90 S.Ct. 1057,1058 , 25 L.Ed.2d 353 , reh’g denied, 398 U.S. 915 , 90 S.Ct. 1684 , 26 L.Ed.2d 80 (1970).

21998–2023
Coleman v. Balkcom, Warden green
scotus · 1981
2 sentences

2023United States v. Alessandrello, 637 F.2d 131, 138 (3d Cir. 1980), cert. denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it ‘embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence’).

1998United States v. AUssandrel-lo, 637 F.2d 131, 138 (3d Cir.1980), cert, denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it “embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence”).

21998–2023
Gray v. Van Ooteghem green
scotus · 1981
2 sentences

2023United States v. Alessandrello, 637 F.2d 131, 138 (3d Cir. 1980), cert. denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it ‘embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence’).

1998United States v. AUssandrel-lo, 637 F.2d 131, 138 (3d Cir.1980), cert, denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it “embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence”).

21998–2023
Ohio Department of Highway Safety v. United States green
scotus · 1981
2 sentences

2023United States v. Alessandrello, 637 F.2d 131, 138 (3d Cir. 1980), cert. denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it ‘embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence’).

1998United States v. AUssandrel-lo, 637 F.2d 131, 138 (3d Cir.1980), cert, denied, 451 U.S. 949 , 101 S.Ct. 2031 , 68 L.Ed.2d 334 (1981) (reasoning Federal Rule 43 is broader than the constitutional right because it “embodies the right to be present derived from the Sixth Amendment Confrontation Clause, the Due Process Clause of the Fifth and Fourteenth Amendments, and the common law privilege of presence”).

21998–2023
State v. Hatch green
nd · 1984
2 sentences

2009This Court explained: “To dismiss a violation of the presence requirement as harmless, it must be ‘determined beyond a reasonable doubt that [the] substantial rights of the defendant are not affected.... ’ • Hatch, 346 N.W.2d at 278 .

1998To dismiss a violation of the presence' requirement as harmless, it must be “determined beyond a reasonable doubt that [the] substantial rights of the defendant are not affected.... ” Hatch, 346 N.W.2d at 278 .

21998–2009
Nash v. United States green
scotus · 1970
1 sentence

2023Illinois v. Allen, 397 U.S. 337, 338 , 90 S.Ct. 1057, 1058 , 25 L.Ed.2d 353 , reh’g denied, 398 U.S. 1 915 , 90 S.Ct. 1684 , 26 L.Ed.2d 80 (1970).

12023–2023
Diaz v. United States green
scotus · 1912
2 sentences

1998In Campbell v. Wood, 18 F.3d 662, 671 (9th Cir. 1994), cert, denied, 511 U.S. 1119 , 114 S.Ct. 2125 , 128 L.Ed.2d 682 (1994), the Ninth Circuit outlined the change: "In Diaz v. United States, 223 U.S. 442, 455 , 32 S.Ct. 250, 254 , 56 L.Ed. 500 (1912), the Court distinguished between capital and noncapital cases and between custodial and noncustodial defendants, stating that the courts have regarded an accused who is in custody and one who is charged with a capital offense as incapable of waiving the right; the one, because his presence or absence is not within his own control, and the other b

1998In Campbell v. Wood, 18 F.3d 662, 671 (9th Cir. 1994), cert, denied, 511 U.S. 1119 , 114 S.Ct. 2125 , 128 L.Ed.2d 682 (1994), the Ninth Circuit outlined the change: "In Diaz v. United States, 223 U.S. 442, 455 , 32 S.Ct. 250, 254 , 56 L.Ed. 500 (1912), the Court distinguished between capital and noncapital cases and between custodial and noncustodial defendants, stating that the courts have regarded an accused who is in custody and one who is charged with a capital offense as incapable of waiving the right; the one, because his presence or absence is not within his own control, and the other b

11998–1998
Illinois v. Allen green
scotus · 1970
1 sentence

1998Illinois v. Allen, 397 U.S. 337, 338 , 90 S.Ct. 1057,1058 , 25 L.Ed.2d 353 , reh’g denied, 398 U.S. 915 , 90 S.Ct. 1684 , 26 L.Ed.2d 80 (1970).

11998–1998
Campbell v. Wood green
scotus · 1994
1 sentence

1998In Campbell v. Wood, 18 F.3d 662, 671 (9th Cir. 1994), cert, denied, 511 U.S. 1119 , 114 S.Ct. 2125 , 128 L.Ed.2d 682 (1994), the Ninth Circuit outlined the change: "In Diaz v. United States, 223 U.S. 442, 455 , 32 S.Ct. 250, 254 , 56 L.Ed. 500 (1912), the Court distinguished between capital and noncapital cases and between custodial and noncustodial defendants, stating that the courts have regarded an accused who is in custody and one who is charged with a capital offense as incapable of waiving the right; the one, because his presence or absence is not within his own control, and the other b

11998–1998
Campbell v. Wood green
scotus · 1994
1 sentence

1998In Campbell v. Wood, 18 F.3d 662, 671 (9th Cir. 1994), cert, denied, 511 U.S. 1119 , 114 S.Ct. 2125 , 128 L.Ed.2d 682 (1994), the Ninth Circuit outlined the change: "In Diaz v. United States, 223 U.S. 442, 455 , 32 S.Ct. 250, 254 , 56 L.Ed. 500 (1912), the Court distinguished between capital and noncapital cases and between custodial and noncustodial defendants, stating that the courts have regarded an accused who is in custody and one who is charged with a capital offense as incapable of waiving the right; the one, because his presence or absence is not within his own control, and the other b

11998–1998

Where else courts name it

CA 168 (1889–2026) NY 126 (1858–2026) IL 120 (1899–2026) TX 110 (1909–2026) AL 86 (1845–2010) PA 83 (1896–2025) WA 56 (1901–2023) GA 56 (1900–2021) MO 52 (1867–2025) WY 47 (1936–2025) TN 41 (1948–2024) IN 38 (1872–2018) LA 36 (1915–2015) NC 32 (1881–2024) MI 32 (1911–2025) OH 31 (1881–2025) NJ 31 (1945–2026) KS 30 (1901–2026) KY 29 (1917–2025) MS 29 (1909–2022) NM 28 (1946–2022) FL 28 (1952–2026) CO 28 (1904–2024) CT 27 (1939–2025) MA 27 (1892–2026) VA 26 (1795–2023) OR 24 (1893–2025) MN 23 (1924–2018) OK 23 (1911–2015) AR 22 (1916–2024) DC 21 (1973–2019) WI 20 (1923–2024) ID 19 (1923–2022) MD 17 (1933–2014) IA 17 (1916–2023) VT 13 (1904–2026) RI 13 (1973–2014) MT 13 (1924–2024) ME 13 (1925–2019) AZ 11 (1920–2009) DE 11 (1981–2025) NE 10 (1905–2020) WV 8 (1981–2003) AK 7 (1972–2019) UT 7 (1985–2024) ND 6 (1971–2023) SD 6 (1913–2013) HI 5 (1977–2021) PR 4 (1918–1966) SC 4 (1936–2016) NH 3 (1951–1995) NV 2 (1987–2021)

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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