resulting error (Vermont) · Go Syfert
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resulting error in Vermont

5 Vermont opinions name it 2 courts 1988–2026 2 in the last five years

The cases below were cited by Vermont 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 (5)

CaseFollowedCited
State v. Gallaghergreen
vt · 1988 · cited in 3 Vermont opinions naming this issue, 1989–2021
2 sentences

2021Gundlah, 166 Vt. at 524 , 702 A.2d at 55 (quoting Richardson v. Marsh, 481 U.S. 200, 208 (1987)); see also State v. Gallagher, 150 Vt. 341, 349 , 554 A.2d 221, 226 (1988) (finding that physician’s hearsay testimony about child’s report of perpetrator of sexual assault was error, but “in view of 11 the merely cumulative nature of the physician’s testimony, and the fact that the child declarant was available for cross-examination, the resulting error was harmless”).

2021Gundlah, 166 Vt. at 524 , 702 A.2d at 55 (quoting Richardson v. Marsh, 481 U.S. 200, 208 (1987)); see also State v. Gallagher, 150 Vt. 341, 349 , 554 A.2d 221, 226 (1988) (finding that physician’s hearsay testimony about child’s report of perpetrator of sexual assault was error, but “in view of 11 the merely cumulative nature of the physician’s testimony, and the fact that the child declarant was available for cross-examination, the resulting error was harmless”).

23
In Re Hawk Mountain Corp.green
vt · 1988 · cited in 1 Vermont opinions naming this issue, 2026–2026
2 sentences

2026The resulting presumption “is merely ‘locative,’ placing the burden of going forward with evidence on the party against whom it operates as a rule of law, but operating without any independent probative value.” In re Hawk Mountain Corp., 149 Vt. 179, 186 (1988) (citation omitted).

2026Rebutting the presumption requires that “credible evidence is introduced fairly and reasonably indicating that the real fact is not as presumed.” Id. (citation omitted).

11
Richardson v. Marshgreen
scotus · 1987 · cited in 1 Vermont opinions naming this issue, 2021–2021
1 sentence

2021Gundlah, 166 Vt. at 524 , 702 A.2d at 55 (quoting Richardson v. Marsh, 481 U.S. 200, 208 (1987)); see also State v. Gallagher, 150 Vt. 341, 349 , 554 A.2d 221, 226 (1988) (finding that physician’s hearsay testimony about child’s report of perpetrator of sexual assault was error, but “in view of 11 the merely cumulative nature of the physician’s testimony, and the fact that the child declarant was available for cross-examination, the resulting error was harmless”).

11
State v. Derouchiegreen
vt · 1989 · cited in 1 Vermont opinions naming this issue, 2006–2006
2 sentences

2006See id. at 33 , 568 A.2d at 418 (holding that hearsay testimony’s admission “had no effect on the outcome of the trial and any... error was harmless” where the testimony was “merely cumulative”); see also Gallagher, 150 Vt. at 349 , 554 A.2d at 226 (“[I]n view of the merely cumulative nature of the physician’s testimony, and the fact that the child declarant was available for cross-examination, the resulting error was harmless.”). ¶ 12.

2006See id. at 33 , 568 A.2d at 418 (holding that hearsay testimony’s admission “had no effect on the outcome of the trial and any... error was harmless” where the testimony was “merely cumulative”); see also Gallagher, 150 Vt. at 349 , 554 A.2d at 226 (“[I]n view of the merely cumulative nature of the physician’s testimony, and the fact that the child declarant was available for cross-examination, the resulting error was harmless.”). ¶ 12.

11
State v. Messiergreen
vt · 1985 · cited in 1 Vermont opinions naming this issue, 1988–1988
2 sentences

1988See State v. Messier, 146 Vt. 145, 157 , 499 A.2d 32, 41 (1985).

1988See State v. Messier, 146 Vt. 145, 157 , 499 A.2d 32, 41 (1985).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
State v. Gundlah green
· 1997
2 sentences

2021Gundlah, 166 Vt. at 524 , 702 A.2d at 55 (quoting Richardson v. Marsh, 481 U.S. 200, 208 (1987)); see also State v. Gallagher, 150 Vt. 341, 349 , 554 A.2d 221, 226 (1988) (finding that physician’s hearsay testimony about child’s report of perpetrator of sexual assault was error, but “in view of 11 the merely cumulative nature of the physician’s testimony, and the fact that the child declarant was available for cross-examination, the resulting error was harmless”).

2021Gundlah, 166 Vt. at 524 , 702 A.2d at 55 (quoting Richardson v. Marsh, 481 U.S. 200, 208 (1987)); see also State v. Gallagher, 150 Vt. 341, 349 , 554 A.2d 221, 226 (1988) (finding that physician’s hearsay testimony about child’s report of perpetrator of sexual assault was error, but “in view of 11 the merely cumulative nature of the physician’s testimony, and the fact that the child declarant was available for cross-examination, the resulting error was harmless”).

12021–2021

Statutes the citing opinions construe

VT § Vt. Stat. Ann. tit. 13, § 3252 (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

IN 429 (1985–2026) CT 44 (1985–2012) CA 36 (1968–2026) IL 27 (1979–2025) TX 25 (1927–2019) NY 20 (1929–2024) PA 14 (1931–2025) DE 13 (1988–2023) FL 12 (1982–2026) OH 11 (1988–2023) TN 10 (1978–2025) MI 10 (1952–2025) WA 10 (1995–2026) GA 10 (1977–2024) MO 8 (1912–2020) WV 8 (1942–2022) LA 7 (1986–2020) MT 7 (1984–2022) OR 7 (1945–2023) MA 6 (1975–2025) NJ 6 (1985–2022) WI 6 (1932–2025) VA 5 (2000–2012) UT 5 (1942–2012) SD 5 (2002–2023) VT 5 (1988–2026) NV 4 (2015–2015) MD 4 (1990–2021) AZ 4 (1996–2020) DC 4 (1976–1994) NM 4 (1982–2002) IA 4 (1995–2009) RI 3 (1994–2015) OK 3 (1961–2001) KY 3 (2024–2026) NC 3 (1951–1999) KS 3 (2005–2025) ME 3 (1985–2020) NE 3 (1994–1998) CO 2 (1995–2019) AR 2 (1974–1975) AL 2 (1979–2014)

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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