party admission exception (Pennsylvania) · Go Syfert
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party admission exception in Pennsylvania

6 Pennsylvania opinions name it 3 courts 1997–2019 0 in the last five years

The cases below were cited by Pennsylvania 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 (5)

CaseFollowedCited
Commonwealth v. Laichgreen
pa · 2001 · cited in 2 Pennsylvania opinions naming this issue, 2005–2019
2 sentences

2019This ruling was proper as it is well-settled that statements made by a defendant are an exception to the hearsay rule. “[A] defendant’s out-of-court statements fall within the party admission exception to the hearsay rule.” Commonwealth v. Laich, 777 A.2d 1057, 1060 (Pa. 2001).

2005See Pa. R.E. 803(25); see also Commonwealth v. Laich, 566 Pa. 19, 26 , 777 A.2d 1057, 1061 (2001) (stating that a defendant’s out-of-court statements fall within the party admission exception to the hearsay rule).

22
Commonwealth v. Smithgreen
pa · 1988 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001Commonwealth v. Smith, 518 Pa. 15 , 540 A.2d 246, 257 (1988).

2001Commonwealth v. Smith, 518 Pa. 15 , 540 A.2d 246, 257 (1988).

11
Vojas v. K Mart Corp.green
illappct · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000See Vojas v. K mart Corp., 312 Ill.App.3d 544 , 245 Ill.Dec. 144 , 727 N.E.2d 397 (2000) (holding the principal’s grant of authority to speak is not the main concern in applying the party-admission exception to the hearsay rule; instead, the test is whether the statement concerns matters within the scope of the employment); Lane v. City of Kotzebue, 982 P.2d 1270, 1273 (Alaska 1999) (stating “An employee’s statements, to be admissible as nonhearsay admissions of party-opponent, do not have to be authorized by the employer; it is enough that they concern the employees’ duties.”).

2000See Vojas v. K mart Corp., 312 Ill.App.3d 544 , 245 Ill.Dec. 144 , 727 N.E.2d 397 (2000) (holding the principal’s grant of authority to speak is not the main concern in applying the party-admission exception to the hearsay rule; instead, the test is whether the statement concerns matters within the scope of the employment); Lane v. City of Kotzebue, 982 P.2d 1270, 1273 (Alaska 1999) (stating “An employee’s statements, to be admissible as nonhearsay admissions of party-opponent, do not have to be authorized by the employer; it is enough that they concern the employees’ duties.”).

11
Lane v. City of Kotzebuegreen
alaska · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000See Vojas v. K mart Corp., 312 Ill.App.3d 544 , 245 Ill.Dec. 144 , 727 N.E.2d 397 (2000) (holding the principal’s grant of authority to speak is not the main concern in applying the party-admission exception to the hearsay rule; instead, the test is whether the statement concerns matters within the scope of the employment); Lane v. City of Kotzebue, 982 P.2d 1270, 1273 (Alaska 1999) (stating “An employee’s statements, to be admissible as nonhearsay admissions of party-opponent, do not have to be authorized by the employer; it is enough that they concern the employees’ duties.”).

2000App.3d 544 , 245 Ill.Dec. 144 , 727 N.E.2d 397 (2000) (holding the principal's grant of authority to speak is not the main concern in applying the party-admission exception to the hearsay rule; instead, the test is whether the statement concerns matters within the scope of the employment); *863 Lane v. City of Kotzebue, 982 P.2d 1270, 1273 (Alaska 1999) (stating "An employee's statements, to be admissible as nonhearsay admissions of party-opponent, do not have to be authorized by the employer; it is enough that they concern the employees' duties.").

11
Commonwealth v. Simmonsgreen
pa · 1995 · cited in 1 Pennsylvania opinions naming this issue, 1997–1997
1 sentence

1997Simmons, supra at 238 , 662 A.2d at 634 (citation omitted).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Senecal v. Commonwealth green
pacommwct · 1981
2 sentences

1999Senecal v. Workmen’s Compensation Appeal Board (Walsh Assoc.), 57 Pa.Cmwlth. 180 , 425 A.2d 1200 , 1203 n.4 (1981)(a statement which falls within the party admission exception to hearsay may be used as substantial evidence).

1999Senecal v. Workmen’s Compensation Appeal Board (Walsh Assoc.), 57 Pa.Cmwlth. 180 , 425 A.2d 1200 , 1203 n.4 (1981)(a statement which falls within the party admission exception to hearsay may be used as substantial evidence).

11999–1999

Where else courts name it

CA 14 (1997–2026) VA 14 (1994–2025) IL 10 (1995–2022) NY 7 (2005–2024) PA 6 (1997–2019) MA 2 (2008–2014) FL 2 (2017–2023)

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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