Case Citator › State v. Laureano

State v. Laureano

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Supreme Court of Washington
Citation
682 P.2d 889
Decided
Confirmed treatments
2
Flagged citations read
27 of 27
Citing cases (total)
27
Treatment dates
1990–1998
Overruled in part
A reviewed court has overruled part of this case’s holding. State v. Laureano was overruled in part on the automatic use of ER 404(b) convictions for impeachment. The Washington Supreme Court's decision in State v. Brown, as reaffirmed on rehearing, rejected that rule.
More on how this was screened

State v. Hutchinson later allowed exclusion of defense evidence as a discovery sanction when a defendant persistently refused a court-ordered examination, narrowing Laureano's categorical bar. Both treatments are listed below. All 27 flagged citations have been read; later courts continue to apply Laureano's other holdings, including its rulings on hypnosis, venue, and other-crimes evidence.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

27 later cases cite State v. Laureano; 27 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on State v. Laureano?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • A conviction admitted as substantive evidence under ER 404(b) is not automatically admissible to impeach the defendant under ER 609(a).

    State v. Brown · Supreme Court of Washington (on rehearing) · filed

    We said in Laureano, at 766, that "when a prior conviction has been admitted as substantive evidence under ER 404(b), that same conviction is admissible as a matter of course for impeachment purposes under ER 609(a)." Upon reflection, we conclude that this statement is incorrect.
    Read the full opinion on CourtListener →

Limited

  • The court allowed exclusion of defense expert testimony for a defendant's persistent refusal to undergo a court-ordered examination, narrowing Laureano's categorical prohibition on exclusion as a discovery sanction.

    State v. Hutchinson · Supreme Court of Washington, en banc · filed

    Glasper therefore held CrR 4.7(h)(7)(i) does not allow the trial court to suppress evidence as a remedy for discovery violations, and Washington courts have consistently followed that holding. See, e.g., State v. Ray, 116 Wash.2d 531, 538, 806 P.2d 1220 (1991); State v. Laureano, 101 Wash.2d 745, 762, 682 P.2d 889 (1984), overruled by State v. Brown, 111 Wash.2d 124, 761 P.2d 588 (1988); State v. Thacker, 94 Wash.2d 276, 280, 616 P.2d 655 (1980). ... While CrR 4.7(h)(7)(i) does not enumerate exclusion as a remedy, it does allow a trial court to "enter such other order as it deems just under the circumstances." This language allows the trial court to impose sanctions not specifically listed in the rule. ... We hold exclusion of the Defendant's experts was warranted in this case.
    Read the full opinion on CourtListener →

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