adverse inference instruction (District of Columbia) · Go Syfert
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adverse inference instruction in District of Columbia

5 District of Columbia opinions name it 1 courts 1991–2019 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.

Followed or applied (13)

CaseFollowedCited
Shelton v. United Statesgreen
dc · 2009 · cited in 1 District of Columbia opinions naming this issue, 2019–2019
1 sentence

2019See Shelton v. United States , 983 A.2d 363 , 369 (D.C. 2009), opinion amended on reh'g , 26 A.3d 216 , 26 A.3d 233 (D.C. 2011).

11
Shelton v. United Statesgreen
dc · 2011 · cited in 1 District of Columbia opinions naming this issue, 2019–2019
1 sentence

2019See Shelton v. United States , 983 A.2d 363 , 369 (D.C. 2009), opinion amended on reh'g , 26 A.3d 216 , 26 A.3d 233 (D.C. 2011).

11
Shelton v. United Statesgreen
dc · 2011 · cited in 1 District of Columbia opinions naming this issue, 2019–2019
1 sentence

2019See Shelton v. United States , 983 A.2d 363 , 369 (D.C. 2009), opinion amended on reh'g , 26 A.3d 216 , 26 A.3d 233 (D.C. 2011).

11
Williams v. United Statesgreen
dc · 1978 · cited in 1 District of Columbia opinions naming this issue, 2001–2001
2 sentences

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent “gross negligence” or “significant prejudice” in failing to preserve Jencks material, court’s decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court’s refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent "gross negligence" or "significant prejudice" in failing to preserve Jencks material, court's decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court's refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

11
Scales v. United Statesgreen
dc · 1996 · cited in 1 District of Columbia opinions naming this issue, 2001–2001
2 sentences

2001See supru Part III, A. Finally, while newly surfaced evidence may give rise to the need for reconsideration of a pretrial suppression decision, see Scales v. United States, 687 A.2d 927, 937 (D.C.1996), and evidence of drug use is relevant to the determination of voluntariness, see (Cullen) Byrd v. United States, 618 A.2d 596, 598 (D.C.1992), the “new evidence” here was far from significant.

2001See supra Part III, A. Finally, while newly surfaced evidence may give rise to the need for reconsideration of a pretrial suppression decision, see Scales v. United States, 687 A.2d 927, 937 (D.C.1996), and evidence of drug use is relevant to the determination of voluntariness, see ( Cullen) Byrd v. United States, 618 A.2d 596, 598 (D.C. 1992), the "new evidence" here was far from significant.

11
Byrd v. United Statesgreen
dc · 1992 · cited in 1 District of Columbia opinions naming this issue, 2001–2001
2 sentences

2001See supru Part III, A. Finally, while newly surfaced evidence may give rise to the need for reconsideration of a pretrial suppression decision, see Scales v. United States, 687 A.2d 927, 937 (D.C.1996), and evidence of drug use is relevant to the determination of voluntariness, see (Cullen) Byrd v. United States, 618 A.2d 596, 598 (D.C.1992), the “new evidence” here was far from significant.

2001See supra Part III, A. Finally, while newly surfaced evidence may give rise to the need for reconsideration of a pretrial suppression decision, see Scales v. United States, 687 A.2d 927, 937 (D.C.1996), and evidence of drug use is relevant to the determination of voluntariness, see ( Cullen) Byrd v. United States, 618 A.2d 596, 598 (D.C. 1992), the "new evidence" here was far from significant.

11
Woodall v. United Statesgreen
dc · 1996 · cited in 1 District of Columbia opinions naming this issue, 2001–2001
2 sentences

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent “gross negligence” or “significant prejudice” in failing to preserve Jencks material, court’s decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court’s refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent "gross negligence" or "significant prejudice" in failing to preserve Jencks material, court's decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court's refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

11
Carpenter v. United Statesgreen
scotus · 1997 · cited in 1 District of Columbia opinions naming this issue, 2001–2001
2 sentences

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent “gross negligence” or “significant prejudice” in failing to preserve Jencks material, court’s decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court’s refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent "gross negligence" or "significant prejudice" in failing to preserve Jencks material, court's decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court's refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

11
Ramos v. United Statesgreen
scotus · 1997 · cited in 1 District of Columbia opinions naming this issue, 2001–2001
2 sentences

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent “gross negligence” or “significant prejudice” in failing to preserve Jencks material, court’s decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court’s refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

2001See Woodall v. United States, 684 A.2d 1258, 1265 (D.C.1996) (absent "gross negligence" or "significant prejudice" in failing to preserve Jencks material, court's decision not to strike testimony was not an abuse of discretion), cert. denied, 520 U.S. 1130 , 117 S.Ct. 1278 , 137 L.Ed.2d 354 (1997); Williams v. United States, 385 A.2d 760, 763 (D.C.1978) (affirming trial court's refusal to strike testimony despite evidence that police officer deliberately destroyed Jencks material).

11
Keller v. Gillgreen
md · 1900 · cited in 1 District of Columbia opinions naming this issue, 1994–1994
2 sentences

1994See Mathews v. O’Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). 28 Indeed, it has been said that “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

1994See Mathews v. O’Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). 28 Indeed, it has been said that “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

11
Mathews v. O'Donnellgreen
· 1921 · cited in 1 District of Columbia opinions naming this issue, 1994–1994
2 sentences

1994See Mathews v. O’Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). 28 Indeed, it has been said that “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

1994See Mathews v. O’Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). 28 Indeed, it has been said that “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

11
Berger v. Bullockgreen
md · 1897 · cited in 1 District of Columbia opinions naming this issue, 1994–1994
2 sentences

1994See Mathews v. O’Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). 28 Indeed, it has been said that “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

1994See Mathews v. O’Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). 28 Indeed, it has been said that “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

11
Brooks v. Daleygreen
md · 1966 · cited in 1 District of Columbia opinions naming this issue, 1994–1994
2 sentences

1994See Mathews v. O'Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). [28] Indeed, it has been said that "the failure to deny charges of fraud is tantamount to an admission of the truth of those charges." Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

1994See Mathews v. O’Donnell, 289 Mo. 235 , 233 S.W. 451, 459 (1921). 28 Indeed, it has been said that “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Brooks, supra, 218 A.2d at 189 (citing Berger v. Bullock, 85 Md. 441 , 37 A. 368, 369 (1897)); see also Keller v. Gill, 92 Md. 190 , 48 A. 69, 71 (1900).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Williams v. Washington Hospital Center green
dc · 1991
2 sentences

2010However, "[w]here the negligence is not intentional or reckless, the court is accorded discretion in determining whether to give an adverse inference instruction and we will not disturb its decision absent an abuse of that discretion." Williams, 601 A.2d at 31 .

2010However, “[w]here the negligence is not intentional or reckless, the court is accorded discretion in determining whether to give an adverse inference instruction and we will not disturb its decision absent an abuse of that discretion.” Williams, 601 A.2d at 31 .

12010–2010
Everett v. Everett green
dc · 1961
2 sentences

1994In Everett v. Everett, 170 A.2d 779, 780 (D.C. 1961), we held that a husband's failure to take the stand in a divorce proceeding to explain statements in a letter which appeared to support his wife's contentions "should have given rise to an inference that his testimony would not have been favorable to his own case." Differences in articulation probably reflect variations in factual context, and we do not take the position that an adverse inference or presumption is mandated in every case.

1994In Everett v. Everett, 170 A.2d 779, 780 (D.C.1961), we held that a husband’s failure to take the stand in a divorce proceeding to explain statements in a letter which appeared to support his wife’s contentions “should have given rise to an inference that his testimony would not have been favorable to his own case.” Differences in articulation probably reflect variations in factual context, and we do not take the position that an adverse inference or presumption is mandated in every case.

11994–1994
Battocchi v. Washington Hospital Center green
dc · 1990
2 sentences

1991Moreover, under Battocchi , even if the trial court does not find “gross indifference or reckless disregard,” it may at its discretion impose an adverse inference instruction after consideration of three factors: [1] “the degree of negligence or bad faith involved, [2] the importance of the evidence lost to the issues at hand, and [3] the availability of other proof enabling the party deprived of the evidence to make the same point.” Battocchi, supra, 581 A.2d at 767 .

1991Moreover, under Battocchi , even if the trial court does not find “gross indifference or reckless disregard,” it may at its discretion impose an adverse inference instruction after consideration of three factors: [1] “the degree of negligence or bad faith involved, [2] the importance of the evidence lost to the issues at hand, and [3] the availability of other proof enabling the party deprived of the evidence to make the same point.” Battocchi, supra, 581 A.2d at 767 .

11991–1991

Where else courts name it

NY 126 (1979–2026) CT 58 (1978–2022) PA 32 (1989–2026) TX 26 (1991–2024) MI 24 (1995–2026) NJ 23 (2001–2026) NV 20 (2004–2022) IL 16 (1992–2025) MO 15 (1987–2019) AZ 12 (2013–2024) DE 10 (2001–2025) CA 9 (2005–2023) CO 7 (1995–2025) WA 7 (2011–2023) SD 6 (1998–2022) WV 6 (1999–2017) ND 6 (1974–2014) MA 5 (1999–2018) DC 5 (1991–2019) AL 4 (1990–2012) NE 3 (1985–2021) FL 3 (2012–2021) MD 3 (1999–2016) OH 3 (2005–2025) OK 3 (2016–2022) LA 3 (1984–2007) GU 2 (2025–2025) NC 2 (2018–2025) VI 2 (2007–2013) IN 2 (1986–2026) TN 2 (2002–2022) NM 2 (2025–2025) NH 2 (1999–2009) UT 2 (2017–2023) IA 2 (2013–2020) KY 2 (2002–2006)

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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