Chapman standard (Virginia) · Go Syfert
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Chapman standard in Virginia

5 Virginia opinions name it 2 courts 1991–2023 1 in the last five years

The cases below were cited by Virginia 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 (7)

CaseFollowedCited
Washington v. Recuencogreen
scotus · 2006 · cited in 2 Virginia opinions naming this issue, 2017–2017
2 sentences

2017As post- Chapman cases from the United States Supreme Court have repeatedly emphasized, all of the factors typically considered in the constitutional-harmless-error doctrine 5 seek to answer a single, ultimate question: • "The question a reviewing court must ask is this: absent the [constitutional error], is it clear beyond a reasonable doubt that the [factfinder] would have returned a verdict of guilty?" Hasting , 461 U.S. at 510 -11 , 103 S.Ct. 1974 (emphasis added) (citing Harrington v. California , 395 U.S. 250 , 254, 89 S.Ct. 1726 , 23 L.Ed.2d 284 (1969) ). • The proper inquiry for consti

2017As post- Chapman cases from the United States Supreme Court have repeatedly emphasized, all of the factors typically considered in the constitutional-harmless-error doctrine 5 seek to answer a single, ultimate question: • "The question a reviewing court must ask is this: absent the [constitutional error], is it clear beyond a reasonable doubt that the [factfinder] would have returned a verdict of guilty?" Hasting , 461 U.S. at 510 -11 , 103 S.Ct. 1974 (emphasis added) (citing Harrington v. California , 395 U.S. 250 , 254, 89 S.Ct. 1726 , 23 L.Ed.2d 284 (1969) ). • The proper inquiry for consti

12
Harrington v. Californiared
scotus · 1969 · cited in 2 Virginia opinions naming this issue, 2017–2017
2 sentences

2017As post- Chapman cases from the United States Supreme Court have repeatedly emphasized, all of the factors typically considered in the constitutional-harmless-error doctrine 5 seek to answer a single, ultimate question: • "The question a reviewing court must ask is this: absent the [constitutional error], is it clear beyond a reasonable doubt that the [factfinder] would have returned a verdict of guilty?" Hasting , 461 U.S. at 510 -11 , 103 S.Ct. 1974 (emphasis added) (citing Harrington v. California , 395 U.S. 250 , 254, 89 S.Ct. 1726 , 23 L.Ed.2d 284 (1969) ). • The proper inquiry for consti

2017As post- Chapman cases from the United States Supreme Court have repeatedly emphasized, all of the factors typically considered in the constitutional-harmless-error doctrine 5 seek to answer a single, ultimate question: • "The question a reviewing court must ask is this: absent the [constitutional error], is it clear beyond a reasonable doubt that the [factfinder] would have returned a verdict of guilty?" Hasting , 461 U.S. at 510 -11 , 103 S.Ct. 1974 (emphasis added) (citing Harrington v. California , 395 U.S. 250 , 254, 89 S.Ct. 1726 , 23 L.Ed.2d 284 (1969) ). • The proper inquiry for consti

12
United States v. Hastinggreen
scotus · 1983 · cited in 2 Virginia opinions naming this issue, 2017–2017
2 sentences

2017As post- Chapman cases from the United States Supreme Court have repeatedly emphasized, all of the factors typically considered in the constitutional-harmless-error doctrine 5 seek to answer a single, ultimate question: • "The question a reviewing court must ask is this: absent the [constitutional error], is it clear beyond a reasonable doubt that the [factfinder] would have returned a verdict of guilty?" Hasting , 461 U.S. at 510 -11 , 103 S.Ct. 1974 (emphasis added) (citing Harrington v. California , 395 U.S. 250 , 254, 89 S.Ct. 1726 , 23 L.Ed.2d 284 (1969) ). • The proper inquiry for consti

2017As post- Chapman cases from the United States Supreme Court have repeatedly emphasized, all of the factors typically considered in the constitutional-harmless-error doctrine 5 seek to answer a single, ultimate question: • "The question a reviewing court must ask is this: absent the [constitutional error], is it clear beyond a reasonable doubt that the [factfinder] would have returned a verdict of guilty?" Hasting , 461 U.S. at 510 -11 , 103 S.Ct. 1974 (emphasis added) (citing Harrington v. California , 395 U.S. 250 , 254, 89 S.Ct. 1726 , 23 L.Ed.2d 284 (1969) ). • The proper inquiry for consti

12
Essex v. Commonwealthgreen
va · 1984 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023Affirmed. 6 Our Supreme Court “has long employed a volitional definition of malice requiring that the ‘wrongful act be done “willfully or purposefully.”’” Flanders v. Commonwealth, 298 Va. 345 , 357 (2020) (quoting Essex v. Commonwealth, 228 Va. 273, 280 (1984)). “[M]alice may be implied from use of a deadly weapon” when committing a homicide.

11
Arizona v. Fulminantegreen
scotus · 1991 · cited in 1 Virginia opinions naming this issue, 1997–1997
2 sentences

1997A federal constitutional error is harmless, and thus excusable, only if it appears “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967); see also Fulminante, 499 U.S. at 296 , 111 S.Ct. at 1257 (applying Chapman test to erroneously admitted confession); Lavinder v. Commonwealth, 12 Va.App. 1003, 1005 , 407 S.E.2d 910, 911 (1991).

1997A federal constitutional error is harmless, and thus excusable, only if it appears “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967); see also Fulminante, 499 U.S. at 296 , 111 S.Ct. at 1257 (applying Chapman test to erroneously admitted confession); Lavinder v. Commonwealth, 12 Va.App. 1003, 1005 , 407 S.E.2d 910, 911 (1991).

11
Lavinder v. Commonwealthgreen
vactapp · 1991 · cited in 1 Virginia opinions naming this issue, 1997–1997
2 sentences

1997A federal constitutional error is harmless, and thus excusable, only if it appears “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967); see also Fulminante, 499 U.S. at 296 , 111 S.Ct. at 1257 (applying Chapman test to erroneously admitted confession); Lavinder v. Commonwealth, 12 Va.App. 1003, 1005 , 407 S.E.2d 910, 911 (1991).

1997A federal constitutional error is harmless, and thus excusable, only if it appears “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967); see also Fulminante, 499 U.S. at 296 , 111 S.Ct. at 1257 (applying Chapman test to erroneously admitted confession); Lavinder v. Commonwealth, 12 Va.App. 1003, 1005 , 407 S.E.2d 910, 911 (1991).

11
Chapman v. Californiared
scotus · 1967 · cited in 1 Virginia opinions naming this issue, 1997–1997
2 sentences

1997A federal constitutional error is harmless, and thus excusable, only if it appears “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967); see also Fulminante, 499 U.S. at 296 , 111 S.Ct. at 1257 (applying Chapman test to erroneously admitted confession); Lavinder v. Commonwealth, 12 Va.App. 1003, 1005 , 407 S.E.2d 910, 911 (1991).

1997A federal constitutional error is harmless, and thus excusable, only if it appears “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967); see also Fulminante, 499 U.S. at 296 , 111 S.Ct. at 1257 (applying Chapman test to erroneously admitted confession); Lavinder v. Commonwealth, 12 Va.App. 1003, 1005 , 407 S.E.2d 910, 911 (1991).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Fahy v. Connecticut green
scotus · 1963
2 sentences

1997The admission of evidence obtained in violation of the federal constitution is reversible error if “there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” Fahy v. Connecticut, 375 U.S. 85, 86-87 , 84 S.Ct. 229, 230 , 11 L.Ed.2d 171 (1963); see Chapman, 386 U.S. at 24 , 87 S.Ct. at 828 (stating that the Chapman test “do[es] no more than adhere to the meaning of [Fahy]”).

1997The admission of evidence obtained in violation of the federal constitution is reversible error if “there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” Fahy v. Connecticut, 375 U.S. 85, 86-87 , 84 S.Ct. 229, 230 , 11 L.Ed.2d 171 (1963); see Chapman, 386 U.S. at 24 , 87 S.Ct. at 828 (stating that the Chapman test “do[es] no more than adhere to the meaning of [Fahy]”).

11997–1997
Mu'Min v. Commonwealth green
va · 1990
2 sentences

1991As recently as Mu'Min v. Commonwealth, 239 Va. 433 , 442 n. 4, 389 S.E.2d 886 , 892 n. 4 (1990), the Supreme Court noted that use of the Chapman standard is not required in reviewing cases of non-constitutional error.

1991As recently as Mu'Min v. Commonwealth, 239 Va. 433 , 442 n. 4, 389 S.E.2d 886 , 892 n. 4 (1990), the Supreme Court noted that use of the Chapman standard is not required in reviewing cases of non-constitutional error.

11991–1991

Statutes the citing opinions construe

VA § Va. Code Ann. § 8.01-678 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 874 (1967–2026) DC 51 (1978–2025) LA 43 (1982–2024) TX 42 (1876–2025) MS 26 (1991–2018) ID 24 (1981–2020) NY 15 (2013–2024) WY 14 (1981–2015) TN 13 (1993–2025) WI 13 (1977–2008) KS 13 (2001–2026) IL 13 (1970–2025) OH 10 (1968–2020) AK 10 (1969–2014) AR 9 (1987–2023) GA 8 (1976–2025) PA 8 (1967–2024) IN 7 (1975–2013) MI 7 (1980–2022) WA 7 (1980–2018) FL 7 (1987–2016) MD 7 (1974–2022) NV 6 (1970–2008) AL 5 (1992–2015) VA 5 (1991–2023) ND 5 (1975–1986) CO 4 (1972–2025) CT 4 (1988–2021) NJ 4 (1968–2005) UT 4 (2003–2025) MA 4 (1978–2018) NE 3 (1988–2020) KY 3 (1969–2008) MO 3 (1985–2011) OR 3 (1981–2020) IA 3 (1991–2016) NM 3 (2004–2009) AZ 2 (1970–1996) MT 2 (1980–1995) OK 2 (2025–2025) SC 2 (1969–1980) MN 2 (1951–2002) ME 2 (1973–1988) DE 2 (2000–2025)

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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