Arizona Revised Statutes
Ariz. Rev. Stat. § 13-3987 (2026)
Harmless error
✓ current as of May 2026
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Neither a departure from the form or mode prescribed in respect to any pleadings or proceedings, nor an error or mistake therein, shall render the pleading or proceeding invalid, unless it actually has prejudiced, or tended to prejudice, the defendant in respect to a substantial right.
Notes of Decisions
Cited in 26
cases (1 in the last 5 years), 1980–2023 · leading case: State v. Ring, 65 P.3d 915 (Ariz. 2003).
State v. Ring, 65 P.3d 915 (Ariz. 2003). “VI, § 27 (2001); accord A.R.S. § 13-3987 (2001). If error is harmless, in these or other cases, substantial justice has been done.”
State v. Hickman, 68 P.3d 418 (Ariz. 2003). “A.R.S. § 13-3987. This statute states that "[n]either a departure from the form or mode prescribed in respect to any pleadings or proceedings, nor an error or mistake therein, shall render the pleadings or proceedings invalid, unless it actually prejudiced, or tended to…”
State v. Vasko, 971 P.2d 189 (Ariz. Ct. App. 1998). “6, § 27; A.R.S. § 13-3987. ¶ 3 We conclude that, in the absence of a showing of prejudice, a speedy trial violation raised as error on appeal after conviction does not warrant reversal of that conviction.”
State of Arizona v. Joseph Javier Romero, 381 P.3d 297 (Ariz. Ct. App. 2016). “Arizona constitutional and statutory law, however, proscribe reversal for a trial error if “substantial justice has been done,” Ariz.”
State v. Huerta, 855 P.2d 776 (Ariz. 1993). “The Arizona legislature has also adopted a statute which is relevant to the issues of this case: Neither a departure from the form or mode prescribed in respect to any pleadings or proceedings, nor an error or mistake therein, shall render the pleading or proceeding invalid,…”
State v. Gendron, 812 P.2d 626 (Ariz. 1991). “For all we know, defendant might have objected had the trial court done what the appeals court now says it was required to do.”
State v. Sullivan, 69 P.3d 1006 (Ariz. Ct. App. 2003). “It is also contrary to statute: “Neither a departure from the form or mode prescribed in respect to any pleadings or proceedings, nor an error or mistake therein, shall render the pleading or proceeding invalid, unless it actually has prejudiced, or tended to prejudice, the…”
State v. White, 815 P.2d 869 (Ariz. 1991). “Whether denominated harmless error, as when dealing with constitutional error, Chapman, supra, or prejudicial error, A.R.S. § 13-3987, as when dealing with non-constitutional error, the test is the same.”
State v. McVay, 622 P.2d 9 (Ariz. 1980). “Whether denominated harmless error, as when dealing with constitutional error, Chapman, supra, or prejudicial error, A.R.S. § 13-3987, as when dealing with non-constitutional error, the test is the same.”
State v. Leonard, 725 P.2d 493 (Ariz. Ct. App. 1986). “” Although the trial court committed error in rejecting the proffered stipulation, it was harmless in light of the other overwhelming evidence against the defendant. Officer McCarthy’s testimony and the defendant’s two intoxilyzer tests were sufficient for conviction.”
Joshua J. v. Arizona Dep't of Econ. Sec., 286 P.3d 166 (Ariz. Ct. App. 2012). “A.R.S. § 13-3987 (2010) (criminal proceedings are not invalidated unless prejudice is shown).”
State v. Thomas, 652 P.2d 1380 (Ariz. 1982). ““Whether denominated harmless error, as when dealing with constitutional error, Chapman, supra, or prejudicial error, A.R.S. § 13-3987, as when dealing with non-constitutional error, the test is the same.”
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