past recollection recorded exception (Florida) · Go Syfert
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past recollection recorded exception in Florida

5 Florida opinions name it 2 courts 1985–2025 1 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 (3)

CaseFollowedCited
McNeal v. Stategreen
fladistctapp · 2013 · cited in 2 Florida opinions naming this issue, 2014–2014
2 sentences

2014In McNeal v. State, 140 So.3d 991 (Fla.2014), the Florida Supreme Court quashed this court’s opinion in McNeal v. State, 109 So.3d 268 (Fla. 1st DCA 2013), to the extent it affirmed the trial court’s decision to allow the State to publish the Victim’s handwritten statement pursuant to the past-recollection recorded exception to the hearsay rule.

2014We have for review McNeal v. State, 109 So.3d 268, 271 (Fla. 1st DCA 2013), in which the First District Court of Appeal found that satisfying the foundational requirements under the past recollection recorded exception to hearsay need not come from the declarant’s testimony. 1 At the time that the First District issued its decision below, Polite v. State, 41 So.3d 935 (Fla. 5th DCA 2010), quashed, 116 So.3d 270 (Fla.2013), was pending review in this Court.

12
Polite v. Stategreen
fla · 2013 · cited in 2 Florida opinions naming this issue, 2014–2014
2 sentences

2014The supreme court remanded “for reconsideration in light of [its] decision in Polite [v. State, 116 So.3d 270 (Fla.2013)], and a proper harmless error analysis under State v. DiGuilio, 491 So.2d 1129 (Fla.1986), if applicable.” McNeal, 140 So.3d at 992 .

2014We have for review McNeal v. State, 109 So.3d 268, 271 (Fla. 1st DCA 2013), in which the First District Court of Appeal found that satisfying the foundational requirements under the past recollection recorded exception to hearsay need not come from the declarant’s testimony. 1 At the time that the First District issued its decision below, Polite v. State, 41 So.3d 935 (Fla. 5th DCA 2010), quashed, 116 So.3d 270 (Fla.2013), was pending review in this Court.

12
Montgomery Ward & Co. v. Rosenquistgreen
fladistctapp · 1959 · cited in 1 Florida opinions naming this issue, 1985–1985
1 sentence

1985In order to qualify as a past recollection recorded, the document in question must, among other things, be "[a] memorandum or record concerning a matter about which a witness once had knowledge, but now has insufficient recollection to enable him to testify fully and accurately... ." § 90.803(5), Fla. Stat. (1983); see Montgomery Ward & Co. v. Rosenquist, 112 So.2d 885 (Fla. 2d DCA 1959).

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 (4)

CaseCitedYears
Hernandez v. State green
fladistctapp · 2010
2 sentences

2025The defense objected, arguing that pursuant to Hernandez v. State, 31 So. 3d 873 (Fla. 4th DCA 2010), and section 90.803(5), Florida Statutes, to have a recorded recollection admitted, the victim must acknowledge that the recorded 5 statement was correct; but this victim did not remember giving the statement.

2013Hernandez, 31 So.3d at 878-79 .

22013–2025
State v. DiGuilio green
fla · 1986
1 sentence

2014The supreme court remanded “for reconsideration in light of [its] decision in Polite [v. State, 116 So.3d 270 (Fla.2013)], and a proper harmless error analysis under State v. DiGuilio, 491 So.2d 1129 (Fla.1986), if applicable.” McNeal, 140 So.3d at 992 .

12014–2014
Polite v. State green
fladistctapp · 2010
1 sentence

2014We have for review McNeal v. State, 109 So.3d 268, 271 (Fla. 1st DCA 2013), in which the First District Court of Appeal found that satisfying the foundational requirements under the past recollection recorded exception to hearsay need not come from the declarant’s testimony. 1 At the time that the First District issued its decision below, Polite v. State, 41 So.3d 935 (Fla. 5th DCA 2010), quashed, 116 So.3d 270 (Fla.2013), was pending review in this Court.

12014–2014
Demetrice Armicle McNeal v. State of Florida neutral
fla · 2014
2 sentences

2014In McNeal v. State, 140 So.3d 991 (Fla.2014), the Florida Supreme Court quashed this court’s opinion in McNeal v. State, 109 So.3d 268 (Fla. 1st DCA 2013), to the extent it affirmed the trial court’s decision to allow the State to publish the Victim’s handwritten statement pursuant to the past-recollection recorded exception to the hearsay rule.

2014The supreme court remanded “for reconsideration in light of [its] decision in Polite [v. State, 116 So.3d 270 (Fla.2013)], and a proper harmless error analysis under State v. DiGuilio, 491 So.2d 1129 (Fla.1986), if applicable.” McNeal, 140 So.3d at 992 .

12014–2014

Statutes the citing opinions construe

FL § 90.803 (4)

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

IL 30 (1967–2024) NY 18 (1980–2023) CA 8 (1981–2026) MA 6 (1980–2011) VA 5 (1989–2016) HI 5 (1999–2019) FL 5 (1985–2025) IN 3 (1980–1998) TX 3 (1974–2009) PA 3 (1981–2015) OR 2 (2019–2026) WI 2 (1968–1992) DC 2 (1976–2003) AL 2 (1998–2015) MI 2 (1975–1977)

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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