nonconstitutional error in Georgia

2021See Adkins v. State, 301 Ga. 153, 158 (3) (a) (800 SE2d 341) (2017) (“A nonconstitutional error is harmless if it is highly probable that the error did not contribute to the verdict”).

2021See Adkins v. State, 301 Ga. 153, 158 (3) (a) (800 SE2d 341) (2017) (“A nonconstitutional error is harmless if it is highly probable that the error did not contribute to the verdict”).

2024“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict[.]” Smith v. State, 313 Ga. 584, 587 (872 SE2d 262) (2022) (citation and punctuation omitted).

2024“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict[.]” Smith v. State, 313 Ga. 584, 587 (872 SE2d 262) (2022) (citation and punctuation omitted).

2023See Jones v. State, 315 Ga. 117, 122 (4) (880 SE2d 509) (2022) (“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict, an inquiry that involves consideration of the other evidence heard by the jury.” (citation and punctuation omitted)); Ward, 313 Ga. at 272 (3) (c) (Any error in admitting the murder victim’s statements about her relationship with the defendant and his pulling a gun on her was harmless where the evidence was largely cumulative of other evidence and the overall evidence of guilt was strong.); Davenpo

2023See Jones v. State, 315 Ga. 117, 122 (4) (880 SE2d 509) (2022) (“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict, an inquiry that involves consideration of the other evidence heard by the jury.” (citation and punctuation omitted)); Ward, 313 Ga. at 272 (3) (c) (Any error in admitting the murder victim’s statements about her relationship with the defendant and his pulling a gun on her was harmless where the evidence was largely cumulative of other evidence and the overall evidence of guilt was strong.); Davenpo

2012The test to determine whether a nonconstitutional error such as the trial court’s failure to sustain an objection to an improper closing argument is reversible error is whether “it is highly probable that the error did not contribute to the judgment.” Johnson v. State, 238 Ga. 59, 61 ( 230 SE2d 869 ) (1976).

2012The test to determine whether a nonconstitutional error such as the trial court’s failure to sustain an objection to an improper closing argument is reversible error is whether “it is highly probable that the error did not contribute to the judgment.” Johnson v. State, 238 Ga. 59, 61 ( 230 SE2d 869 ) (1976).

2023See Jones v. State, 315 Ga. 117, 122 (4) (880 SE2d 509) (2022) (“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict, an inquiry that involves consideration of the other evidence heard by the jury.” (citation and punctuation omitted)); Ward, 313 Ga. at 272 (3) (c) (Any error in admitting the murder victim’s statements about her relationship with the defendant and his pulling a gun on her was harmless where the evidence was largely cumulative of other evidence and the overall evidence of guilt was strong.); Davenpo

2023See Jones v. State, 315 Ga. 117, 122 (4) (880 SE2d 509) (2022) (“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict, an inquiry that involves consideration of the other evidence heard by the jury.” (citation and punctuation omitted)); Ward, 313 Ga. at 272 (3) (c) (Any error in admitting the murder victim’s statements about her relationship with the defendant and his pulling a gun on her was harmless where the evidence was largely cumulative of other evidence and the overall evidence of guilt was strong.); Davenpo

2026See Allen v. State, 317 Ga. 1, 8 (2023) (“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict.”) (citation and punctuation omitted).

2023See Allen v. State, ___ Ga. ___, ___ (890 SE2d 700, 708) (2023) (“‘A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict.’”) (citation omitted).

2022A nonconstitutional error is “harmless if the State 9 shows that it is highly probable that the error did not contribute to the verdict, an inquiry that involves consideration of the other evidence heard by the jury.” State v. Lane, 308 Ga. 10, 21 (838 SE2d 808) (2020) (citation and punctuation omitted).

2022A nonconstitutional error is “harmless if the State 9 shows that it is highly probable that the error did not contribute to the verdict, an inquiry that involves consideration of the other evidence heard by the jury.” State v. Lane, 308 Ga. 10, 21 (838 SE2d 808) (2020) (citation and punctuation omitted).

2025See Rivera v. State, 295 Ga. 380, 382 ( 761 SE2d 30 ) (2014).

2025See Rivera v. State, 295 Ga. 380, 382 ( 761 SE2d 30 ) (2014).

2025See 10 Sharkey v. State, 320 Ga. 477, 483 (910 SE2d 216) (2024) (“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict.”) (cleaned up). (a) At trial, the State sought to introduce Ware’s death certificate through the testimony of the Johnson County coroner.

2025See 10 Sharkey v. State, 320 Ga. 477, 483 (910 SE2d 216) (2024) (“A nonconstitutional error is harmless if the State shows that it is highly probable that the error did not contribute to the verdict.”) (cleaned up). (a) At trial, the State sought to introduce Ware’s death certificate through the testimony of the Johnson County coroner.

2025A nonconstitutional error is harmless if the State shows that “it is highly probable that the error did not contribute to the verdict[.]” Pounds v. State, 320 Ga. 288, 294 ( 908 SE2d 631 ) (2024) (citation and punctuation omitted).

2025A nonconstitutional error is harmless if the State shows that “it is highly probable that the error did not contribute to the verdict[.]” Pounds v. State, 320 Ga. 288, 294 ( 908 SE2d 631 ) (2024) (citation and punctuation omitted).

2024In conducting that analysis, “we assess the evidence from the viewpoint of reasonable jurors, not in the light most favorable to the verdicts.” Hatney v. State, 308 Ga. 438, 441 (2) (841 SE2d 702) (2020).

2024In conducting that analysis, “we assess the evidence from the viewpoint of reasonable jurors, not in the light most favorable to the verdicts.” Hatney v. State, 308 Ga. 438, 441 (2) (841 SE2d 702) (2020).

2023“In determining whether trial court error was harmless, we review the record de novo, and we weigh the evidence as we would expect reasonable jurors to have done so as opposed to viewing it all in the light most favorable to the jury’s verdict.” Morrell v. State, 313 Ga. 247, 261 (2) (c) (869 SE2d 447) (2022) (citation and punctuation omitted).

2023“In determining whether trial court error was harmless, we review the record de novo, and we weigh the evidence as we would expect reasonable jurors to have done so as opposed to viewing it all in the light most favorable to the jury’s verdict.” Morrell v. State, 313 Ga. 247, 261 (2) (c) (869 SE2d 447) (2022) (citation and punctuation omitted).

2022See Elliott, 305 Ga. at 223 (IV) (E).

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2022See Bannister v. State, 306 Ga. 289, 301 (5) (b) (830 SE2d 79) (2019).

2022See Bannister v. State, 306 Ga. 289, 301 (5) (b) (830 SE2d 79) (2019).

2022In determining whether the error was harmless, “we review the record de novo, and we weigh the evidence as we would expect reasonable jurors to have done so as opposed to viewing it all in the light most favorable to the jury’s verdict.” Finney v. State, 311 Ga. 1, 13 (3) (a) (855 SE2d 578) (2021).

2022In determining whether the error was harmless, “we review the record de novo, and we weigh the evidence as we would expect reasonable jurors to have done so as opposed to viewing it all in the light most favorable to the jury’s verdict.” Finney v. State, 311 Ga. 1, 13 (3) (a) (855 SE2d 578) (2021).

2022See Harris, 301 Ga. at 240 (2).8 If all of the text messages put together, including the ones in which Harris appeared to acknowledge his plans to rob and kill someone, Proof of such statements is original evidence; it is not an exception to hearsay.” Bundrage v. State, 265 Ga. 813, 814 (2) (462 SE2d 719) (1995) (citation and punctuation omitted). 8 We made that determination under a standard different than the one that we would apply in considering whether a nonconstitutional error by the trial court were harmless, which requires the State to show that it is highly probable that the error did

2022See Harris, 301 Ga. at 240 (2).8 If all of the text messages put together, including the ones in which Harris appeared to acknowledge his plans to rob and kill someone, Proof of such statements is original evidence; it is not an exception to hearsay.” Bundrage v. State, 265 Ga. 813, 814 (2) (462 SE2d 719) (1995) (citation and punctuation omitted). 8 We made that determination under a standard different than the one that we would apply in considering whether a nonconstitutional error by the trial court were harmless, which requires the State to show that it is highly probable that the error did

2022See Harris, 301 Ga. at 240 (2).8 If all of the text messages put together, including the ones in which Harris appeared to acknowledge his plans to rob and kill someone, Proof of such statements is original evidence; it is not an exception to hearsay.” Bundrage v. State, 265 Ga. 813, 814 (2) (462 SE2d 719) (1995) (citation and punctuation omitted). 8 We made that determination under a standard different than the one that we would apply in considering whether a nonconstitutional error by the trial court were harmless, which requires the State to show that it is highly probable that the error did

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2022See State v. Herrera-Bustamante, 304 Ga. 259, 262-263 (2) (a) ( 818 SE2d 552 ) (2018). 12 Vaughn v. State, 248 Ga. 127, 131 (2) ( 281 SE2d 594 ) (1981) (citation and punctuation omitted); see Brown v. State, 262 Ga. 833, 836 (10) ( 426 SE2d 559 ) (1993). 13 Mangum v. State, 274 Ga. 573, 577 (2) ( 555 SE2d 451 ) (2001). 14 Although the State referenced the standard for a nonconstitutional error, the present case involves a constitutional error as Porter’s right to refuse is grounded in his right against self-incrimination under Article I, Section I, Paragraph VXI of the Georgia Constitution of

2020In assessing whether a trial court’s error was harmful, “we weigh the evidence as we would expect reasonable jurors to have done so, as opposed to assuming that they took the most pro-guilt possible view of every bit of evidence in the case.” Boothe v. State, 293 Ga. 285, 289 (2) (b) ( 745 SE2d 594 ) (2013) (footnote omitted).

2020In assessing whether a trial court’s error was harmful, “we weigh the evidence as we would expect reasonable jurors to have done so, as opposed to assuming that they took the most pro-guilt possible view of every bit of evidence in the case.” Boothe v. State, 293 Ga. 285, 289 (2) (b) ( 745 SE2d 594 ) (2013) (footnote omitted).

2020The trial court simply ruled — a ruling well within its discretion — that the cross- examination needed to proceed in a fair manner and that, when 5 That statute provides: “In examining a witness concerning a prior statement made by the witness, whether written or not, the statement need not be shown nor its contents disclosed to the witness at that time. . . .” OCGA § 24-6-613 (a). 6 To show that a nonconstitutional error was harmless, the State must demonstrate “that it was highly probable that the error did not contribute to the verdict.” Bozzie v. State, 302 Ga. 704, 708 (2) (a) ( 808 SE2d

2020The trial court simply ruled — a ruling well within its discretion — that the cross- examination needed to proceed in a fair manner and that, when 5 That statute provides: “In examining a witness concerning a prior statement made by the witness, whether written or not, the statement need not be shown nor its contents disclosed to the witness at that time. . . .” OCGA § 24-6-613 (a). 6 To show that a nonconstitutional error was harmless, the State must demonstrate “that it was highly probable that the error did not contribute to the verdict.” Bozzie v. State, 302 Ga. 704, 708 (2) (a) ( 808 SE2d

2019“A nonconstitutional error is harmless if it is highly probable that the error did not contribute to the verdict.” Jones v. State, 305 Ga. 653, 657 (3) ( 827 SE2d 254 ) (2019) (citation and punctuation omitted).

2019“A nonconstitutional error is harmless if it is highly probable that the error did not contribute to the verdict.” Jones v. State, 305 Ga. 653, 657 (3) ( 827 SE2d 254 ) (2019) (citation and punctuation omitted).

2017See Lindsey v. State, 282 Ga. 447, 450 (2) ( 651 SE2d 66 ) (2007).

2017See Lindsey v. State, 282 Ga. 447, 450 (2) ( 651 SE2d 66 ) (2007).

1996"The correct inquiry is whether, assuming that the damaging potential of the cross-examination [was] fully realized, a reviewing court might nonetheless say that the error was harmless beyond a reasonable doubt." Delaware v. Van Arsdall, 475 U.S. 673, 684 , 106 S.Ct. 1431, 1438 , 89 L.Ed.2d 674 (1986).

1996"The correct inquiry is whether, assuming that the damaging potential of the cross-examination [was] fully realized, a reviewing court might nonetheless say that the error was harmless beyond a reasonable doubt." Delaware v. Van Arsdall, 475 U.S. 673, 684 , 106 S.Ct. 1431, 1438 , 89 L.Ed.2d 674 (1986).

1996That same test was applied to a nonconstitutional error in such cases as Barrett v. State, 263 Ga. 533, 535 (2), 436 S.E.2d 480 (1993), and Teague v. State, 252 Ga. 534, 537 (2), 314 S.E.2d 910 (1984), and by this Court in Cobb v. State, 209 Ga.App. 708, 709 , 434 S.E.2d 513 (1993).

1996That same test was applied to a nonconstitutional error in such cases as Barrett v. State, 263 Ga. 533, 535 (2), 436 S.E.2d 480 (1993), and Teague v. State, 252 Ga. 534, 537 (2), 314 S.E.2d 910 (1984), and by this Court in Cobb v. State, 209 Ga.App. 708, 709 , 434 S.E.2d 513 (1993).

1996That same test was applied to a nonconstitutional error in such cases as Barrett v. State, 263 Ga. 533, 535 (2), 436 S.E.2d 480 (1993), and Teague v. State, 252 Ga. 534, 537 (2), 314 S.E.2d 910 (1984), and by this Court in Cobb v. State, 209 Ga.App. 708, 709 , 434 S.E.2d 513 (1993).

1996That same test was applied to a nonconstitutional error in such cases as Barrett v. State, 263 Ga. 533, 535 (2), 436 S.E.2d 480 (1993), and Teague v. State, 252 Ga. 534, 537 (2), 314 S.E.2d 910 (1984), and by this Court in Cobb v. State, 209 Ga.App. 708, 709 , 434 S.E.2d 513 (1993).

1996That same test was applied to a nonconstitutional error in such cases as Barrett v. State, 263 Ga. 533, 535 (2), 436 S.E.2d 480 (1993), and Teague v. State, 252 Ga. 534, 537 (2), 314 S.E.2d 910 (1984), and by this Court in Cobb v. State, 209 Ga.App. 708, 709 , 434 S.E.2d 513 (1993).

1996That same test was applied to a nonconstitutional error in such cases as Barrett v. State, 263 Ga. 533, 535 (2), 436 S.E.2d 480 (1993), and Teague v. State, 252 Ga. 534, 537 (2), 314 S.E.2d 910 (1984), and by this Court in Cobb v. State, 209 Ga.App. 708, 709 , 434 S.E.2d 513 (1993).