182 Oregon opinions name it 4 courts 1917–2026 82 in the last five years
The cases below were cited by Oregon 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.
| Case | Followed | Cited |
|---|---|---|
State v. Hortongreen2 sentences2025We cannot reverse a judgment based on a harmless error, so if the error was truly ‘harmless,’ then we have no discretion and must affirm.” State v. Horton, 327 Or App 256, 262 , 535 P3d 338 (2023); see also State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (“Oregon’s constitutional test for affirmance despite error consists of a single inquiry: Is there little likelihood that the particular error affected the verdict?”); State v. M. 2025We cannot reverse a judgment based on a harmless error, so if the error was truly ‘harmless,’ then we have no discretion and must affirm.” State v. Horton, 327 Or App 256, 262 , 535 P3d 338 (2023); see also State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (“Oregon’s constitutional test for affirmance despite error consists of a single inquiry: Is there little likelihood that the particular error affected the verdict?”); State v. M. | 11 | 22 |
State v. Davisgreen2 sentences2025We cannot reverse a judgment based on a harmless error, so if the error was truly ‘harmless,’ then we have no discretion and must affirm.” State v. Horton, 327 Or App 256, 262 , 535 P3d 338 (2023); see also State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (“Oregon’s constitutional test for affirmance despite error consists of a single inquiry: Is there little likelihood that the particular error affected the verdict?”); State v. M. 2025We cannot reverse a judgment based on a harmless error, so if the error was truly ‘harmless,’ then we have no discretion and must affirm.” State v. Horton, 327 Or App 256, 262 , 535 P3d 338 (2023); see also State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (“Oregon’s constitutional test for affirmance despite error consists of a single inquiry: Is there little likelihood that the particular error affected the verdict?”); State v. M. | 10 | 36 |
Arizona v. Fulminantegreen2 sentences2020The Court recognized that “an involuntary confession may have a more dramatic effect on the course of a trial than do other trial errors—in partic- ular cases it may be devastating to a defendant—but this simply means that a reviewing court will conclude in such a case that its admission was not harmless error; it is not a reason for eschewing the harmless-error test entirely.” Fulminante, 499 US at 312 . 2020Erosion of Public Confidence Finally, defendant argues that a nonunanimous jury instruction constitutes structural error because it “erodes public confidence in the jury-trial right.” However, the Supreme Court has emphasized that “the harmless-error doctrine is essential to preserve the ‘principle that the central purpose of a criminal trial is to decide the factual question of the defendant’s guilt or innocence, and promotes public respect for the criminal process by focusing on the underlying fairness of the trial rather than on the virtually inevitable presence of immaterial error.’ ” Fulm | 3 | 6 |
Delaware v. Van Arsdallgreen2 sentences2020Erosion of Public Confidence Finally, defendant argues that a nonunanimous jury instruction constitutes structural error because it “erodes public confidence in the jury-trial right.” However, the Supreme Court has emphasized that “the harmless-error doctrine is essential to preserve the ‘principle that the central purpose of a criminal trial is to decide the factual question of the defendant’s guilt or innocence, and promotes public respect for the criminal process by focusing on the underlying fairness of the trial rather than on the virtually inevitable presence of immaterial error.’ ” Fulm 2008Although some errors are subject to automatic reversal under federal law, Neder v. US, 527 US 1, 8 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999), violations of a defendant’s Sixth Amendment confrontation right are subject to a harmless error review, Delaware v. Van Arsdall, 475 US 673, 684 , 106 S Ct 1431 , 89 L Ed 2d 674 (1986) (“Accordingly, we hold that the constitutionally improper denial of a defendant’s opportunity to impeach a witness for bias, like other Confrontation Clause errors, is subject to Chapman harmless-error analysis.”); see also State v. Cook, 340 Or 530, 543-44 ,135 P3d 260 *275 | 3 | 4 |
State v. Perkinsgreen2 sentences2024See State v. Horton, 327 Or App 256, 262 , 535 P3d 338 (2023) (“We cannot reverse a judgment based on a harmless error, so if the error was truly ‘harmless,’ then we have no discretion and must affirm” as to that challenge); see also State v. Perkins, 325 Or App 624 , 529 P3d 999 (2023) (establishing the beyond-a-reasonable-doubt standard). 2024See State v. Horton, 327 Or App 256, 262 , 535 P3d 338 (2023) (“We cannot reverse a judgment based on a harmless error, so if the error was truly ‘harmless,’ then we have no discretion and must affirm” as to that challenge); see also State v. Perkins, 325 Or App 624 , 529 P3d 999 (2023) (establishing the beyond-a-reasonable-doubt standard). | 3 | 3 |
State v. Dinsmoregreen2 sentences2016See State v. Dinsmore, 182 Or App 505, 519 , 49 P3d 830 (2002) (explaining that “[e]mploying a harmless error analysis would defeat [defendant’s] statutory right [under ORS 135.335(3)]. 2016See State v. Dinsmore, 182 Or App 505, 519 , 49 P3d 830 (2002) (explaining that “[e]mploying a harmless error analysis would defeat [defendant’s] statutory right [under ORS 135.335(3)]. | 2 | 7 |
State v. Zaldana-Mendozagreen2 sentences2025See, e.g., State v. Zaldana-Mendoza, 299 Or App 590, 613 , 450 P3d 983 (2019) (explaining that when conducting a harmless-error analysis, “we do not usurp the role of the factfinder and determine if defendant is guilty or reweigh the evidence”). 2025See, e.g., State v. Zaldana-Mendoza, 299 Or App 590, 613 , 450 P3d 983 (2019) (explaining that when conducting a harmless-error analysis, “we do not usurp the role of the factfinder and determine if defendant is guilty or reweigh the evidence”). | 2 | 6 |
State v. Leachgreen2 sentences2025See State v. Leach, 294 Or App 639, 646 , 432 P3d 310 (2018) (explaining that we have consistently declined to engage in a harmless error analysis in appeals arising from conditional pleas under ORS 135.335(3)). 2025See State v. Leach, 294 Or App 639, 646 , 432 P3d 310 (2018) (explaining that we have consistently declined to engage in a harmless error analysis in appeals arising from conditional pleas under ORS 135.335(3)). | 2 | 5 |
State v. Garciagreen2 sentences2024An “error is harmless if there is little likelihood that the error affected the verdict or substantially affected the defendant’s rights.” State v. Garcia, 284 Or App 357, 363 , 392 P3d 815 , rev den, 361 Or 645 (2017). 2024An “error is harmless if there is little likelihood that the error affected the verdict or substantially affected the defendant’s rights.” State v. Garcia, 284 Or App 357, 363 , 392 P3d 815 , rev den, 361 Or 645 (2017). | 2 | 5 |
State v. Waltongreen2 sentences2003The corroboration is sufficient for the statements to be admissible, and the trial court erred in excluding them. [7] We turn to whether the trial court's error affected defendant's substantial rightsthat is, whether or not it was harmless. [8] OEC 103(1)(b). [9] Defendant, relying on State v. Joslin, 332 Or. 373, 387 , 29 P.3d 1112 (2001), states the standard for harmless error as whether there is "`(1) substantial and compelling evidence of guilt * * *, and (2) little, if any, likelihood that the error affected the verdict.'" (Quoting State v. Walton, 311 Or. 223, 230 , 809 P.2d 81 (1991).) 2003The corroboration is sufficient for the statements to be admissible, and the trial court erred in excluding them. [7] We turn to whether the trial court's error affected defendant's substantial rightsthat is, whether or not it was harmless. [8] OEC 103(1)(b). [9] Defendant, relying on State v. Joslin, 332 Or. 373, 387 , 29 P.3d 1112 (2001), states the standard for harmless error as whether there is "`(1) substantial and compelling evidence of guilt * * *, and (2) little, if any, likelihood that the error affected the verdict.'" (Quoting State v. Walton, 311 Or. 223, 230 , 809 P.2d 81 (1991).) | 2 | 5 |
State v. Klontzgreen2 sentences2017See State v. Klontz, 257 Or App 684, 702-03 , 308 P3d 214 (2013) (concluding that the harmless error analysis in a bench trial where the trial court failed to mention contested evidence when explaining its disposition is “contextually driven” and that we must ask “ [w] as the disputed evidence ultimately material to the resolution of issues disputed at trial?”). 2017See State v. Klontz, 257 Or App 684, 702-03 , 308 P3d 214 (2013) (concluding that the harmless error analysis in a bench trial where the trial court failed to mention contested evidence when explaining its disposition is “contextually driven” and that we must ask “ [w] as the disputed evidence ultimately material to the resolution of issues disputed at trial?”). | 2 | 3 |
State v. Pagegreen2 sentences2025See, e.g., State v. Page, 290 Or App 562, 567 , 415 P3d 1139 (2018) (so stating and observ- ing that the legislature left the choice to the defendant to withdraw the conditional plea). 2025See, e.g., State v. Page, 290 Or App 562, 567 , 415 P3d 1139 (2018) (so stating and observ- ing that the legislature left the choice to the defendant to withdraw the conditional plea). | 2 | 2 |
State v. Sanchez-Alfonsogreen2 sentences2025See State v. Sanchez-Alfonso, 352 Or 790, 807-08 , 293 P3d 1011 (2012) (declining to “speculate about what may have happened if the case had been tried otherwise” in the harmless error analysis). 2025See State v. Sanchez-Alfonso, 352 Or 790, 807-08 , 293 P3d 1011 (2012) (declining to “speculate about what may have happened if the case had been tried otherwise” in the harmless error analysis). | 2 | 2 |
| Washington v. Recuencogreen | 2 | 2 |
State v. Hernandezgreen2 sentences2023See Hernandez, 294 Kan at 208, 273 P3d at 779 (“When the trial record shows evidence of age that was overwhelming and essentially uncontroverted, the failure to give the jury an instruction on the element of age * * * may be harmless.”); see also Washington v. Recuenco, 548 US 212 , 126 S Ct 2546 , 165 L Ed 2d 466 (2006) (holding that the failure to submit a sentencing factor to the jury under Apprendi is not struc- tural error and is subject to a harmless-error analysis). 2023See Hernandez, 294 Kan at 208, 273 P3d at 779 (“When the trial record shows evidence of age that was overwhelming and essentially uncontroverted, the failure to give the jury an instruction on the element of age * * * may be harmless.”); see also Washington v. Recuenco, 548 US 212 , 126 S Ct 2546 , 165 L Ed 2d 466 (2006) (holding that the failure to submit a sentencing factor to the jury under Apprendi is not struc- tural error and is subject to a harmless-error analysis). | 2 | 2 |
| State v. Ashkinsgreen | 2 | 2 |
| State v. Inmangreen | 2 | 2 |
| Montara Owners Assn. v. La Noue Development, LLCgreen | 2 | 2 |
| State v. Mendoza-Sanchezgreen | 2 | 2 |
| State v. Lowellgreen | 2 | 2 |
| State v. Cookgreen | 2 | 2 |
State v. Colegreen2 sentences2005In State v. Cole, 323 Or 30 , 912 P2d 907 (1996), the court declined to apply a harmless error analysis in the context of a waiver of counsel where the defendant was not sufficiently apprised of the risks of representing himself at a suppression hearing as required by Meyrick . 2005In State v. Cole, 323 Or 30 , 912 P2d 907 (1996), the court declined to apply a harmless error analysis in the context of a waiver of counsel where the defendant was not sufficiently apprised of the risks of representing himself at a suppression hearing as required by Meyrick . | 1 | 3 |
Rose v. Clarkgreen2 sentences1995Harmless-error analysis thus presupposes a trial, at which the defendant, represented by counsel, may present evidence and argument before an impartial judge and jury.” Rose, 478 US at 577-78 , 92 L Ed 2d at 470 (citations omitted). 1995Harmless-error analysis thus presupposes a trial, at which the defendant, represented by counsel, may present evidence and argument before an impartial judge and jury." Rose, 478 U.S. at 577-78 , 106 S.Ct. at 3106 , 92 L.Ed.2d at 470 (citations omitted). | 1 | 3 |
State v. Sperougreen2 sentences2026See State v. Sperou, 365 Or 121, 140 , 442 P3d 581 (2019) (holding that the trial court’s error in denying a defendant’s pretrial motion to exclude vouching testimony was not a harmless error, and noting that, “[i]n general, wit- ness vouching in Oregon is considered prejudicial, so much so in fact that it sometimes requires intervention by the trial court even when parties fail to object to it”); State v. Milbradt, 305 Or 621, 630 , 756 P2d 620 (1988) (suggesting that, if a question seeks to elicit vouching testimony, “the trial judge, sua sponte, should summarily cut off the inquiry before a 2026See State v. Sperou, 365 Or 121, 140 , 442 P3d 581 (2019) (holding that the trial court’s error in denying a defendant’s pretrial motion to exclude vouching testimony was not a harmless error, and noting that, “[i]n general, wit- ness vouching in Oregon is considered prejudicial, so much so in fact that it sometimes requires intervention by the trial court even when parties fail to object to it”); State v. Milbradt, 305 Or 621, 630 , 756 P2d 620 (1988) (suggesting that, if a question seeks to elicit vouching testimony, “the trial judge, sua sponte, should summarily cut off the inquiry before a | 1 | 2 |
| State v. Simongreen | 1 | 2 |
| Graham v. Howtongreen | 1 | 2 |
| State v. Hansengreen | 1 | 2 |
| State v. Cunninghamgreen | 1 | 2 |
| State v. Vanornumgreen | 1 | 1 |
| State v. Wyattgreen | 1 | 1 |
| Superior Protection, Inc. v. National Labor Relations Boardgreen | 1 | 1 |
| State v. McKinney/Shiffergreen | 1 | 1 |
| State v. Rusengreen | 1 | 1 |
| Ryan v. Palmateergreen | 1 | 1 |
| State v. Antoinegreen | 1 | 1 |
| State v. Paynegreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Parker
green
2 sentences2021Under the harmless- error doctrine, we will affirm despite the error if “there is little likelihood that a particular error affected the verdict.” Davis, 336 Or at 32 (quoting State v. Parker, 317 Or 225 , 234 n 10, 855 P2d 636 (1993)) (internal quotation marks, brackets, and ellipses in Davis omitted); see also OEC 103 (stating that evidential error is not presumed prejudicial and that error may not be predicated upon a ruling to admit or exclude evidence unless a substantial right has been affected). 2021Under the harmless- error doctrine, we will affirm despite the error if “there is little likelihood that a particular error affected the verdict.” Davis, 336 Or at 32 (quoting State v. Parker, 317 Or 225 , 234 n 10, 855 P2d 636 (1993)) (internal quotation marks, brackets, and ellipses in Davis omitted); see also OEC 103 (stating that evidential error is not presumed prejudicial and that error may not be predicated upon a ruling to admit or exclude evidence unless a substantial right has been affected). | 6 | 1994–2021 |
State v. McGinnis
green
2 sentences2023As the state notes, in State v. McGinnis, 335 Or 243, 247 , 64 P3d 1123 (2003), the court considered, and rejected, a defen- dant’s argument that the court “adopt a rule that precludes consideration of a defendant’s trial testimony in a harmless error review when the defendant’s tes- timony was compelled to rebut illegally admitted evidence.” The court concluded that any such rule could not be invoked “unless the evidence the defendant sought to rebut by taking the stand was an inadmissible confession, not evidence of some other kind, even if that evidence was obtained illegally.” Id. at 253 . 2023As the state notes, in State v. McGinnis, 335 Or 243, 247 , 64 P3d 1123 (2003), the court considered, and rejected, a defen- dant’s argument that the court “adopt a rule that precludes consideration of a defendant’s trial testimony in a harmless error review when the defendant’s tes- timony was compelled to rebut illegally admitted evidence.” The court concluded that any such rule could not be invoked “unless the evidence the defendant sought to rebut by taking the stand was an inadmissible confession, not evidence of some other kind, even if that evidence was obtained illegally.” Id. at 253 . | 4 | 2006–2023 |
Chapman v. California
red
2 sentences2020Assuming that a harmless error analysis applies, the receipt of a nonunanimous verdict cannot be found “harmless beyond a reasonable doubt.” Chapman v. Cite as 366 Or 500 (2020) 505 California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967) (setting forth the harmless error standard applicable to violations of the federal constitution). 2020Assuming that a harmless error analysis applies, the receipt of a nonunanimous verdict cannot be found “harmless beyond a reasonable doubt.” Chapman v. Cite as 366 Or 500 (2020) 505 California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967) (setting forth the harmless error standard applicable to violations of the federal constitution). | 4 | 1993–2020 |
Neder v. United States
green
2 sentences2025Neder v. United States, 527 US 1, 18 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999) (stating the harmless error standard applicable to violations of the Sixth Amendment jury-trial right). 2025Neder v. United States, 527 US 1, 18 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999) (stating the harmless error standard applicable to violations of the Sixth Amendment jury-trial right). | 3 | 2008–2025 |
State v. Holbrook
green
2 sentences2009State v. Ennis, 212 Or App 240, 262 , 158 P3d 510 , rev den, 343 Or 223 (2007). 2008In determining whether an evidentiary error is harmless, a reviewing court should consider “the importance of the evidence, whether the evidence was cumulative, the presence or absence of evidence corroborating or contradicting the evidence, and the overall strength of the prosecution’s case.” State v. Ennis, 212 Or App 240, 262 , 158 P3d 510 , rev den, 343 Or 223 (2007) (citing Van Arsdall, 475 US at 684 ; Cook, 340 Or at 544 ). | 3 | 2007–2009 |
State v. Ennis
green
2 sentences2009State v. Ennis, 212 Or App 240, 262 , 158 P3d 510 , rev den, 343 Or 223 (2007). 2009State v. Ennis, 212 Or App 240, 262 , 158 P3d 510 , rev den, 343 Or 223 (2007). | 3 | 2007–2009 |
State v. Van Hooser
green
2 sentences1979I am unable, however, to agree with the flat application of the harmless error rule of State v. Van Hooser, 266 Or. 19 , 511 P.2d 359 (1973), at least without further analysis than the majority affords the question. 1979I am unable, however, to agree with the flat application of the harmless error rule of State v. Van Hooser, 266 Or. 19 , 511 P.2d 359 (1973), at least without further analysis than the majority affords the question. | 3 | 1979–1982 |
State v. G. K. S.
green
2 sentences2025Although not framed as a harmless error argument, the gravamen of the state’s argument is that we should affirm the adjudication for fourth-degree assault on an aiding and abetting theory because the court could have accomplished precisely what it ended up doing even though it failed to grant youth’s Cite as 337 Or App 535 (2025) 541 motion to dismiss. 2025Although not framed as a harmless error argument, the gravamen of the state’s argument is that we should affirm the adjudication for fourth-degree assault on an aiding and abetting theory because the court could have accomplished precisely what it ended up doing even though it failed to grant youth’s Cite as 337 Or App 535 (2025) 541 motion to dismiss. | 2 | 2025–2025 |
State v. Lander
neutral
2 sentences2025Viewing the record as a whole—given the evidence presented, defendant’s theory of the case, and the instruc- tions that were given—we conclude that the likelihood that Nonprecedential Memo Op: 339 Or App 641 (2025) 645 the trial court’s alleged instructional error effected the ver- dict is extremely low. 2025Viewing the record as a whole—given the evidence presented, defendant’s theory of the case, and the instruc- tions that were given—we conclude that the likelihood that Nonprecedential Memo Op: 339 Or App 641 (2025) 645 the trial court’s alleged instructional error effected the ver- dict is extremely low. | 2 | 2025–2025 |
State v. M. T. F.
green
2 sentences2025F., 326 Or App 371, 380 , 532 P3d 913 , rev den, 371 Or 476 (2023) (applying the harmless error analysis in a delinquency case). 2025F., 326 Or App 371, 380 , 532 P3d 913 , rev den, 371 Or 476 (2023) (applying the harmless error analysis in a delinquency case). | 2 | 2025–2025 |
State v. Leckenby
green
2 sentences2025Cf. State v. Leckenby, 200 Or App 684, 690 , 117 P3d 273 (2005) (failure to instruct on a lesser- included offense is not a harmless error because “the jury did not have a complete statement of the law that applied to the case” and that may have impacted the outcome).1 1 The state argues any error is harmless because evidence supports instruc- tion on the choice-of-evils defense only for the acquitted escape charge and not defendant’s attempt-to-elude charge. 2025Cf. State v. Leckenby, 200 Or App 684, 690 , 117 P3d 273 (2005) (failure to instruct on a lesser- included offense is not a harmless error because “the jury did not have a complete statement of the law that applied to the case” and that may have impacted the outcome).1 1 The state argues any error is harmless because evidence supports instruc- tion on the choice-of-evils defense only for the acquitted escape charge and not defendant’s attempt-to-elude charge. | 2 | 2012–2025 |
State v. Martineau
green
2 sentences2024State v. Martineau, 300 Or App 784, 790-91 , 455 P3d 1020 (2019) (internal quotation marks omitted). 2019Cite as 300 Or App 784 (2019) 791 State v. Blanchard, 236 Or App 472, 476 , 236 P3d 845 (2010) (“Under the Sixth Amendment, a court’s denial of a defen- dant’s right to be self-represented is ‘structural error’ that is not subject to harmless error analysis.” (Quoting United States v. Gonzalez-Lopez, 548 US 140, 149-50 , 126 S Ct 2557 , 165 L Ed 2d 409 (2006); McKaskle v. Wiggins, 465 US 168 , 177-78 n 8, 104 S Ct 944 , 79 L Ed 2d 122 (1984).)); Miller, 254 Or App at 524 (reversing for a new trial without conducting a harmless error analysis). | 2 | 2019–2024 |
State v. Joyce
green
2 sentences2024As we recently explained, “[e]rror regarding a defendant’s state constitutional right to self-representation is subject to the harmless error doc- trine, which precludes reversal if there is little likelihood that the particular error affected the verdict.” State v. Joyce, 332 Or App 580, 582 , 549 P3d 581 (2024) (internal quotation marks omitted). 2024As we recently explained, “[e]rror regarding a defendant’s state constitutional right to self-representation is subject to the harmless error doc- trine, which precludes reversal if there is little likelihood that the particular error affected the verdict.” State v. Joyce, 332 Or App 580, 582 , 549 P3d 581 (2024) (internal quotation marks omitted). | 2 | 2024–2024 |
| Portfolio Recovery Assocs., LLC v. Sanders green | 2 | 2023–2023 |
| Salinas v. Dillman green | 2 | 2017–2023 |
| State v. Ramoz green | 2 | 2023–2023 |
| State v. Delaney green | 2 | 2023–2023 |
| State v. Moore/Coen green | 2 | 2017–2023 |
| State v. Flores Ramos green | 2 | 2021–2022 |
| State v. Stewart green | 2 | 2022–2022 |
| Schneble v. Florida green | 2 | 2020–2021 |
| State v. Blanchard green | 2 | 2019–2019 |
| State v. Marks green | 2 | 2017–2018 |
| State v. Maiden green | 2 | 2014–2016 |
| State v. Ashkins neutral | 2 | 2015–2015 |
| Rushen v. Spain green | 2 | 1991–1996 |
| State v. Woodford green | 1 | 2026–2026 |
| State v. Milbradt green | 1 | 2026–2026 |
| State v. Johnson neutral | 1 | 2025–2025 |
| State v. Rudolph neutral | 1 | 2024–2024 |
| State v. McGaughey neutral | 1 | 2024–2024 |
| Ramirez v. Northwest Renal Clinic green | 1 | 2024–2024 |
| State v. Dye green | 1 | 2023–2023 |
| O'Donnell v. Johnson green | 1 | 2023–2023 |
| State v. Green green | 1 | 2023–2023 |
| State v. Davis-McCoy green | 1 | 2023–2023 |
| State v. Meighan green | 1 | 2023–2023 |
| State v. Serrano (A173250) green | 1 | 2023–2023 |
| State v. Serrano neutral | 1 | 2023–2023 |
| State v. Barone green | 1 | 2023–2023 |
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.
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.