obviousness requirement (Utah) · Go Syfert
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obviousness requirement in Utah

5 Utah opinions name it 2 courts 1989–2026 1 in the last five years

The cases below were cited by Utah 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 (6)

CaseFollowedCited
State v. Eldredgegreen
utah · 1989 · cited in 3 Utah opinions naming this issue, 1993–2010
2 sentences

2010However, even assuming arguendo that the error should have been obvious to the trial court, cf. State v. Eldredge, 773 P.2d 29 , 35 n. 8 (Utah) (noting "that the obviousness requirement poses no rigid and insurmountable barrier to review" and stating that even if the misstatements are not "obvious," the court may "dispense with the requirement of obviousness so that justice can be done"), cert. denied, 493 U.S. 814 , 110 S.Ct. 62 , 107 L.Ed.2d 29 (1989), an error is harmful only if it undermines our confidence in the verdict or, put another way, if "there is a reasonable likelihood of a more f

1999See State v. Eldredge, 773 P.2d 29, 36 (Utah 1989) (holding that the obviousness of an error is hard to determine where there is no settled appellate law on point); State v. Emmett, 839 P.2d 781, 786 (Utah 1992) (relying on the “clarity of the law in this area” to find that error should have been obvious); State v. Baker, 963 P.2d 801, 805 (Utah Ct.App.1998) (refusing to find plain error where there is no settled case law in the state). ¶ 79 In conclusion, I concur in the result.

13
State v. Bullockgreen
utah · 1989 · cited in 1 Utah opinions naming this issue, 2010–2010
1 sentence

2010Plain error will not be found, however, "if a party through counsel has made a conscious decision to refrain from objecting." State v. Bullock, 791 P.2d 155, 158 (Utah 1989), cert. denied, 497 U.S. 1024 , 110 S.Ct. 3270 , 111 L.Ed.2d 780 (1990). ¶ 29 We do not conclude that either the prosecution's "few seconds" statement or its characterization of "What if I lied?," taken alone, are so harmful as to undermine our confidence in the verdict.

11
State v. Bakergreen
utahctapp · 1998 · cited in 1 Utah opinions naming this issue, 1999–1999
2 sentences

1999See State v. Eldredge, 773 P.2d 29, 36 (Utah 1989) (holding that the obviousness of an error is hard to determine where there is no settled appellate law on point); State v. Emmett, 839 P.2d 781, 786 (Utah 1992) (relying on the “clarity of the law in this area” to find that error should have been obvious); State v. Baker, 963 P.2d 801, 805 (Utah Ct.App.1998) (refusing to find plain error where there is no settled case law in the state). ¶ 79 In conclusion, I concur in the result.

1999See State v. Eldredge, 773 P.2d 29, 36 (Utah 1989) (holding that the obviousness of an error is hard to determine where there is no settled appellate law on point); State v. Emmett, 839 P.2d 781, 786 (Utah 1992) (relying on the "clarity of the law in this area" to find that error should have been obvious); State v. Baker, 963 P.2d 801, 805 (Utah Ct.App. 1998) (refusing to find plain error where there is no settled case law in the state). ¶ 79 In conclusion, I concur in the result.

11
State v. Emmettgreen
utah · 1992 · cited in 1 Utah opinions naming this issue, 1999–1999
2 sentences

1999See State v. Eldredge, 773 P.2d 29, 36 (Utah 1989) (holding that the obviousness of an error is hard to determine where there is no settled appellate law on point); State v. Emmett, 839 P.2d 781, 786 (Utah 1992) (relying on the “clarity of the law in this area” to find that error should have been obvious); State v. Baker, 963 P.2d 801, 805 (Utah Ct.App.1998) (refusing to find plain error where there is no settled case law in the state). ¶ 79 In conclusion, I concur in the result.

1999See State v. Eldredge, 773 P.2d 29, 36 (Utah 1989) (holding that the obviousness of an error is hard to determine where there is no settled appellate law on point); State v. Emmett, 839 P.2d 781, 786 (Utah 1992) (relying on the "clarity of the law in this area" to find that error should have been obvious); State v. Baker, 963 P.2d 801, 805 (Utah Ct.App. 1998) (refusing to find plain error where there is no settled case law in the state). ¶ 79 In conclusion, I concur in the result.

11
State v. Poegreen
utah · 1970 · cited in 1 Utah opinions naming this issue, 1989–1989
2 sentences

1989See State v. Poe, 21 Utah 2d 113 , 441 P.2d 512 (1968), appeal after remand, 24 Utah 2d 355 , 471 P.2d 870 (1970); Utah R.Evid. 103(d) advisory committee's note. [8] We note that the two plain error requirements of obviousness and harmfulness are related and that the obviousness requirement poses no rigid and insurmountable barrier to review.

1989See State v. Poe, 21 Utah 2d 113 , 441 P.2d 512 (1968), appeal after remand, 24 Utah 2d 355 , 471 P.2d 870 (1970); Utah R.Evid. 103(d) advisory committee's note. [8] We note that the two plain error requirements of obviousness and harmfulness are related and that the obviousness requirement poses no rigid and insurmountable barrier to review.

11
State v. Poegreen
utah · 1968 · cited in 1 Utah opinions naming this issue, 1989–1989
2 sentences

1989See State v. Poe, 21 Utah 2d 113 , 441 P.2d 512 (1968), appeal after remand, 24 Utah 2d 355 , 471 P.2d 870 (1970); Utah R.Evid. 103(d) advisory committee's note. [8] We note that the two plain error requirements of obviousness and harmfulness are related and that the obviousness requirement poses no rigid and insurmountable barrier to review.

1989See State v. Poe, 21 Utah 2d 113 , 441 P.2d 512 (1968), appeal after remand, 24 Utah 2d 355 , 471 P.2d 870 (1970); Utah R.Evid. 103(d) advisory committee's note. [8] We note that the two plain error requirements of obviousness and harmfulness are related and that the obviousness requirement poses no rigid and insurmountable barrier to review.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Utah. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
State v. Griffin green
utah · 2016
2 sentences

2026And since plain error review requires a showing of both an error and the obviousness of that error, see State v. Griffin, 2016 UT 33, ¶ 17 , 384 P.3d 186 , we reject this claim under plain error too.

2026And since plain error review requires a showing of both an error and the obviousness of that error, see State v. Griffin, 2016 UT 33, ¶ 17 , 384 P.3d 186 , we reject this claim under plain error too.

12026–2026
State v. Dunn green
utah · 1993
1 sentence

2010However, even assuming arguendo that the error should have been obvious to the trial court, cf. State v. Eldredge, 773 P.2d 29 , 35 n. 8 (Utah) (noting "that the obviousness requirement poses no rigid and insurmountable barrier to review" and stating that even if the misstatements are not "obvious," the court may "dispense with the requirement of obviousness so that justice can be done"), cert. denied, 493 U.S. 814 , 110 S.Ct. 62 , 107 L.Ed.2d 29 (1989), an error is harmful only if it undermines our confidence in the verdict or, put another way, if "there is a reasonable likelihood of a more f

12010–2010
Endsley v. Young green
scotus · 1990
1 sentence

2010Plain error will not be found, however, "if a party through counsel has made a conscious decision to refrain from objecting." State v. Bullock, 791 P.2d 155, 158 (Utah 1989), cert. denied, 497 U.S. 1024 , 110 S.Ct. 3270 , 111 L.Ed.2d 780 (1990). ¶ 29 We do not conclude that either the prosecution's "few seconds" statement or its characterization of "What if I lied?," taken alone, are so harmful as to undermine our confidence in the verdict.

12010–2010
Parker v. Dugger green
scotus · 1990
1 sentence

2010Plain error will not be found, however, "if a party through counsel has made a conscious decision to refrain from objecting." State v. Bullock, 791 P.2d 155, 158 (Utah 1989), cert. denied, 497 U.S. 1024 , 110 S.Ct. 3270 , 111 L.Ed.2d 780 (1990). ¶ 29 We do not conclude that either the prosecution's "few seconds" statement or its characterization of "What if I lied?," taken alone, are so harmful as to undermine our confidence in the verdict.

12010–2010
Erickson v. City of Webster Groves green
scotus · 1989
1 sentence

2010However, even assuming arguendo that the error should have been obvious to the trial court, cf. State v. Eldredge, 773 P.2d 29 , 35 n. 8 (Utah) (noting "that the obviousness requirement poses no rigid and insurmountable barrier to review" and stating that even if the misstatements are not "obvious," the court may "dispense with the requirement of obviousness so that justice can be done"), cert. denied, 493 U.S. 814 , 110 S.Ct. 62 , 107 L.Ed.2d 29 (1989), an error is harmful only if it undermines our confidence in the verdict or, put another way, if "there is a reasonable likelihood of a more f

12010–2010
LaMon v. Butler green
scotus · 1989
1 sentence

2010However, even assuming arguendo that the error should have been obvious to the trial court, cf. State v. Eldredge, 773 P.2d 29 , 35 n. 8 (Utah) (noting "that the obviousness requirement poses no rigid and insurmountable barrier to review" and stating that even if the misstatements are not "obvious," the court may "dispense with the requirement of obviousness so that justice can be done"), cert. denied, 493 U.S. 814 , 110 S.Ct. 62 , 107 L.Ed.2d 29 (1989), an error is harmful only if it undermines our confidence in the verdict or, put another way, if "there is a reasonable likelihood of a more f

12010–2010
Martinez v. United States green
scotus · 1989
1 sentence

2010However, even assuming arguendo that the error should have been obvious to the trial court, cf. State v. Eldredge, 773 P.2d 29 , 35 n. 8 (Utah) (noting "that the obviousness requirement poses no rigid and insurmountable barrier to review" and stating that even if the misstatements are not "obvious," the court may "dispense with the requirement of obviousness so that justice can be done"), cert. denied, 493 U.S. 814 , 110 S.Ct. 62 , 107 L.Ed.2d 29 (1989), an error is harmful only if it undermines our confidence in the verdict or, put another way, if "there is a reasonable likelihood of a more f

12010–2010

Where else courts name it

ME 22 (1982–2025) UT 5 (1989–2026) CO 5 (2011–2022) TX 4 (2013–2014) MI 3 (2018–2018) OR 3 (2014–2024)

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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