Case Citator › United States v. Ilario M.A. Zannino

United States v. Ilario M.A. Zannino

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

Abrogated
Court
First Circuit
Citation
895 F.2d 1
Decided
Confirmed treatments
1
Flagged citations read
33 of 33
Citing cases (total)
33
Treatment dates
1990
Abrogated
A reviewed court treats this case as abrogated by later authority. United States v. Zannino was abrogated on one evidentiary point: corroborating trial evidence cannot establish a hearsay statement's trustworthiness under the Confrontation Clause. In United States v. Nelson Bernardo Gomez-Lemos, the Sixth Circuit identified the conflict with the Supreme Court's later decision in Idaho v. Wright.
More on how this was screened

Zannino's separate rule that undeveloped appellate arguments are waived remains regularly applied. All 33 flagged citations have been read. The confirmed adverse treatment is listed below.

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.

33 later cases cite United States v. Ilario M.A. Zannino; 33 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 United States v. Ilario M.A. Zannino?

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

Abrogated

  • The Supreme Court rejected reliance on corroborating trial evidence to establish a hearsay statement's trustworthiness under the Confrontation Clause, contrary to Zannino's earlier analysis.

    Idaho v. Wright · Supreme Court of the United States · filed

    As our discussion above suggests, we are unpersuaded by the State’s contention that evidence corroborating the truth of a hearsay statement may properly support a finding that the statement bears “particularized guarantees of trustworthiness.” To be admissible under the Confrontation Clause, hearsay evidence used to convict a defendant must possess indicia of reliability by virtue of its inherent trustworthiness, not by reference to other evidence at trial.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads United States v. Ilario M.A. Zannino and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace