Case Citator › United States v. York

United States v. York

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

Overruled in part
Court
Seventh Circuit
Citation
933 F.2d 1343
Decided
Confirmed treatments
2
Flagged citations read
32 of 32
Citing cases (total)
32
Treatment dates
1993–1999
Overruled in part
A reviewed court has overruled part of this case’s holding. United States v. York is overruled in part. All 32 flagged citations have been read.
More on how this was screened

The Seventh Circuit en banc overruled York's rule that a party must always repeat a pretrial evidentiary objection at trial to preserve it for appeal. The Fifth Circuit also rejected York's reasoning about statements against penal interest. The 2 confirmed treatments are listed below; later courts still cite York on other evidentiary issues.

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.

32 later cases cite United States v. York; 32 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. York?

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

  • The Seventh Circuit en banc overruled York's requirement to renew an objection at trial when the district court definitively decided the fully presented issue before trial.

    Wilson v. Williams · Seventh Circuit (en banc) · filed

    We overrule York to the extent it holds that an objection at trial is invariably required to preserve for appeal arguments that were fully presented to the district court before trial.
    Read the full opinion on CourtListener →

Declined to Follow

  • The Fifth Circuit declined York's reasoning that declarations against penal interest form a firmly rooted hearsay exception.

    United States v. Flores · Fifth Circuit · filed

    The York court concluded that the issue of whether the exception for declarations against penal interest was firmly rooted was still open, and then held that it was a firmly rooted exception. Id. We decline to follow this reasoning because exceptions are firmly rooted precisely because such exceptions contain statements that are presumptively reliable.
    Read the full opinion on CourtListener →

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