federal constitutional error (Montana) · Go Syfert
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federal constitutional error in Montana

27 Montana opinions name it 1 courts 1971–2010 0 in the last five years

The cases below were cited by Montana 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
Satterwhite v. Texasgreen
scotus · 1988 · cited in 2 Montana opinions naming this issue, 2000–2008
2 sentences

2000Before a federal constitutional error can be held harmless under Chapman , the reviewing “court must be able to declare a belief that it was harmless beyond a reasonable doubt.” Chapman, 386 U.S. at 24 , 87 S.Ct. at 828 , 17 L.Ed.2d at 710-11 . ¶40 In Satterwhite v. Texas (1988), 486 U.S. 249 , 108 S.Ct. 1792 , 100 L.Ed.2d 284 , the U.S. Supreme Court distinguished between those Sixth Amendment transgressions that are subject to harmless error review and those violations that trigger a rule of automatic reversal: “We have permitted harmless error analysis in both capital and noncapital cases w

2000Before a federal constitutional error can be held harmless under Chapman , the reviewing “court must be able to declare a belief that it was harmless beyond a reasonable doubt.” Chapman, 386 U.S. at 24 , 87 S.Ct. at 828 , 17 L.Ed.2d at 710-11 . ¶40 In Satterwhite v. Texas (1988), 486 U.S. 249 , 108 S.Ct. 1792 , 100 L.Ed.2d 284 , the U.S. Supreme Court distinguished between those Sixth Amendment transgressions that are subject to harmless error review and those violations that trigger a rule of automatic reversal: “We have permitted harmless error analysis in both capital and noncapital cases w

22
Gas Products Co. v. Rankingreen
mont · 1922 · cited in 2 Montana opinions naming this issue, 2008–2008
2 sentences

2008Along these same lines, we have stated that where the constitutionality of a governmental act affecting property rights is attacked under both the United States Constitution and the Montana Constitution, “we believe it to be our duty, irrespective of the holdings of other courts, to consider and apply the provisions of our own Constitution and general statutes thereto, and declare the rule of property for Montana.” Gas Products Co. v. Rankin, 63 Mont. 372, 388 , 207 P. 993, 997-98 (1922).

2008Along these same lines, we have stated that where the constitutionality of a governmental act affecting property rights is attacked under both the United States Constitution and the Montana Constitution, “we believe it to be our duty, irrespective of the holdings of other courts, to consider and apply the provisions of our own Constitution and general statutes thereto, and declare the rule of property for Montana.” Gas Products Co. v. Rankin, 63 Mont. 372, 388 , 207 P. 993, 997-98 (1922).

22
Buckman v. Montana Deaconess Hospitalgreen
mont · 1986 · cited in 2 Montana opinions naming this issue, 2008–2008
2 sentences

2008We have also said that “we will not reach a federal constitutional challenge unless and until the case may not be resolved on adequate and independent state grounds.” Buckman v. Montana Deaconess Hosp., 224 Mont. 318, 325 , 730 P.2d 380, 384 (1986).

2008We have also said that “we will not reach a federal constitutional challenge unless and until the case may not be resolved on adequate and independent state grounds.” Buckman v. Montana Deaconess Hosp., 224 Mont. 318, 325 , 730 P.2d 380, 384 (1986).

22
Chapman v. Californiared
scotus · 1967 · cited in 16 Montana opinions naming this issue, 1979–2008
2 sentences

2008Before a federal constitutional error can be held harmless under Chapman , the reviewing court “must be able to declare a belief that it was harmless beyond a reasonable doubt.” Chapman, 386 U.S. at 24 , 87 S. Ct. at 828 .

2008Before a federal constitutional error can be held harmless under Chapman , the reviewing court “must be able to declare a belief that it was harmless beyond a reasonable doubt.” Chapman, 386 U.S. at 24 , 87 S. Ct. at 828 .

116
Brecht v. Abrahamsongreen
scotus · 1993 · cited in 1 Montana opinions naming this issue, 2008–2008
2 sentences

2008Critically, “[t]he State bears the burden of proving that an error passes muster under this standard.” Brecht v. Abrahamson, 507 U.S. 619, 630 , 113 S. Ct. 1710, 1717 (1993); see also Chapman, 386 U.S. at 24 , 87 S. Ct. at 828 (“[T]he original common-law harmless-error rule put the burden on the beneficiary of the error either to prove that there was no injury or to suffer a reversal of his erroneously obtained judgment.”). ¶31 At the same time, the Supreme Court has recognized that “[s]ome constitutional violations ... by their very nature cast so much doubt on the fairness of the trial proce

2008Critically, “[t]he State bears the burden of proving that an error passes muster under this standard.” Brecht v. Abrahamson, 507 U.S. 619, 630 , 113 S. Ct. 1710, 1717 (1993); see also Chapman, 386 U.S. at 24 , 87 S. Ct. at 828 (“[T]he original common-law harmless-error rule put the burden on the beneficiary of the error either to prove that there was no injury or to suffer a reversal of his erroneously obtained judgment.”). ¶31 At the same time, the Supreme Court has recognized that “[s]ome constitutional violations ... by their very nature cast so much doubt on the fairness of the trial proce

11
State v. Geraldgreen
nj · 1988 · cited in 1 Montana opinions naming this issue, 1996–1996
2 sentences

1996Resort to a state-constitutional analysis is especially appropriate in light of the fact that “capital punishment is a matter of particular state interest or local concern and does not require a uniform national policy.” Gerald, 549 A.2d at 810-11 (citation omitted).

1996Resort to a state-constitutional analysis is especially appropriate in light of the fact that "capital punishment is a matter of particular state interest or local concern and does not require a uniform national policy." Gerald, 549 A.2d at 810-11 (citation omitted).

11
Harrington v. Californiared
scotus · 1969 · cited in 1 Montana opinions naming this issue, 1979–1979
2 sentences

1979Chapman, 386 U.S. at 24 , 87 S.Ct. 824 ; see also Harrington v. California (1969), 395 U.S. 250 , 89 S.Ct. 1726 , 23 L.Ed.2d 284 ; Schneble v. Florida (1972), 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 .

1979Chapman, 386 U.S. at 24 , 87 S.Ct. 824 ; see also Harrington v. California (1969), 395 U.S. 250 , 89 S.Ct. 1726 , 23 L.Ed.2d 284 ; Schneble v. Florida (1972), 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
Fahy v. Connecticut green
scotus · 1963
2 sentences

1987“The federal constitutional test of harmless error is whether there *153 is a reasonable possibility that the evidence complained of might have contributed to the conviction.” State v. Roberts (Mont. 1981), 633 P.2d 1214, 1218 , 38 St.Rep. 1551 , 1555 citing Fahy v. Connecticut (1963), 375 U.S. 85 , 84 S.Ct. 229 , 11 L.Ed.2d 171 .

1987“The federal constitutional test of harmless error is whether there *153 is a reasonable possibility that the evidence complained of might have contributed to the conviction.” State v. Roberts (Mont. 1981), 633 P.2d 1214, 1218 , 38 St.Rep. 1551 , 1555 citing Fahy v. Connecticut (1963), 375 U.S. 85 , 84 S.Ct. 229 , 11 L.Ed.2d 171 .

51981–1987
Oyler v. Boles green
scotus · 1962
2 sentences

1998Maldonado, 176 Mont. at 329 , 578 P.2d at 300 (citing Oyler v. Boles (1962), 368 U.S. 448, 456 , 82 S.Ct. 501, 506 , 7 L.Ed.2d 446 ).

1998Maldonado, 176 Mont. at 329 , 578 P.2d at 300 (citing Oyler v. Boles (1962), 368 U.S. 448, 456 , 82 S.Ct. 501, 506 , 7 L.Ed.2d 446 ).

21978–1998
Brown v. MacDonald neutral
mont · 2007
2 sentences

2010Brown v. McDonald, 2007 MT 197, ¶ 12 , 338 Mont. 390 , 165 P.3d 1125 (citations omitted). ¶59 [6] Griffith satisfies the first part of the § 1983 analysis because her federal constitutional right to free speech, as guaranteed by the First Amendment, was violated when she was prohibited from delivering her valedictory speech.

2010Brown v. McDonald, 2007 MT 197, ¶ 12 , 338 Mont. 390 , 165 P.3d 1125 (citations omitted). ¶59 [6] Griffith satisfies the first part of the § 1983 analysis because her federal constitutional right to free speech, as guaranteed by the First Amendment, was violated when she was prohibited from delivering her valedictory speech.

12010–2010
State v. Maldonado green
mont · 1978
2 sentences

1998State v. Maldonado (1978), 176 Mont. 322, 328-29 , 578 P.2d 296, 300 . “[T]he conscious exercise of some selectivity in enforcement is not in itself a federal constitutional violation” absent an allegation and showing that “the selection was deliberately based upon an unjustifiable standard such as race, religion, or other arbitrary classifi cation” such as sex, or the exercise of the First Amendment right to free speech.

1998State v. Maldonado (1978), 176 Mont. 322, 328-29 , 578 P.2d 296, 300 . “[T]he conscious exercise of some selectivity in enforcement is not in itself a federal constitutional violation” absent an allegation and showing that “the selection was deliberately based upon an unjustifiable standard such as race, religion, or other arbitrary classifi cation” such as sex, or the exercise of the First Amendment right to free speech.

11998–1998
State v. Rothacher green
mont · 1995
2 sentences

1996In State v. Rothacher (1995), 272 Mont. 303 , 901 P.2d 82 , we quoted with approval a 1967 United States Supreme Court case wherein that Court stated that “before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt.” Rothacher, 901 P.2d at 87 (quoting Chapman v. California (1967), 386 U.S. 18,24 , 87 S.Ct. 824, 828 , 17 L.Ed.2d 705 ).

1996In State v. Rothacher (1995), 272 Mont. 303 , 901 P.2d 82 , we quoted with approval a 1967 United States Supreme Court case wherein that Court stated that “before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt.” Rothacher, 901 P.2d at 87 (quoting Chapman v. California (1967), 386 U.S. 18,24 , 87 S.Ct. 824, 828 , 17 L.Ed.2d 705 ).

11996–1996
James v. Kentucky green
scotus · 1984
2 sentences

1995James v. Kentucky (1984), 466 U.S. 341 , 104 S.Ct. 1830 , 80 L.Ed.2d 346 .

1995James v. Kentucky (1984), 466 U.S. 341 , 104 S.Ct. 1830 , 80 L.Ed.2d 346 .

11995–1995
State v. Roberts green
mont · 1981
1 sentence

1987“The federal constitutional test of harmless error is whether there *153 is a reasonable possibility that the evidence complained of might have contributed to the conviction.” State v. Roberts (Mont. 1981), 633 P.2d 1214, 1218 , 38 St.Rep. 1551 , 1555 citing Fahy v. Connecticut (1963), 375 U.S. 85 , 84 S.Ct. 229 , 11 L.Ed.2d 171 .

11987–1987
Bordenkircher v. Hayes green
scotus · 1978
2 sentences

1984Within the limits set by the legislature’s constitutionally valid definition of chargeable offenses, ‘the conscious exercise of some selectivity in enforcement is not in itself a federal constitutional violation’ so long as ‘the selection was [not] deliberately based upon an unjustifiable standard such as race, religion, or other arbitrary classification.’ (Citing cases)” Bordenkircher v. Hayes (1978), 434 U.S. 357, 364 , 98 S.Ct. 663 , 54 L.Ed.2d 604, 611 .

1984Within the limits set by the legislature’s constitutionally valid definition of chargeable offenses, ‘the conscious exercise of some selectivity in enforcement is not in itself a federal constitutional violation’ so long as ‘the selection was [not] deliberately based upon an unjustifiable standard such as race, religion, or other arbitrary classification.’ (Citing cases)” Bordenkircher v. Hayes (1978), 434 U.S. 357, 364 , 98 S.Ct. 663 , 54 L.Ed.2d 604, 611 .

11984–1984
State v. Howard green
mont · 1981
1 sentence

1982Chapman v. California (1967), 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 .” 637 P.2d at 17-18 .

11982–1982
Anderson v. Ball green
scotus · 1961
1 sentence

1981Chapman v. California (1967), 368 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 .

11981–1981
Schneble v. Florida green
scotus · 1972
2 sentences

1979Chapman, 386 U.S. at 24 , 87 S.Ct. 824 ; see also Harrington v. California (1969), 395 U.S. 250 , 89 S.Ct. 1726 , 23 L.Ed.2d 284 ; Schneble v. Florida (1972), 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 .

1979Chapman, 386 U.S. at 24 , 87 S.Ct. 824 ; see also Harrington v. California (1969), 395 U.S. 250 , 89 S.Ct. 1726 , 23 L.Ed.2d 284 ; Schneble v. Florida (1972), 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 .

11979–1979
Jackson v. Denno green
scotus · 1964
2 sentences

1971Jackson v. Denno, 378 U.S. 368 , 84 S.Ct. 1774 , 12 L.Ed.2d 908 .

1971Jackson v. Denno, 378 U.S. 368 , 84 S.Ct. 1774 , 12 L.Ed.2d 908 .

11971–1971

Statutes the citing opinions construe

MT § Mont. Code Ann. § 46-20-701 (7) MT § Mont. Code Ann. § 45-5-102 (6) MT § Mont. Code Ann. § 46-20-702 (5) MT § Mont. Code Ann. § 45-5-202 (4) MT § Mont. Code Ann. § 45-6-204 (4) MT § Mont. Code Ann. § 1-2-101 (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 589 (1966–2026) TX 294 (1968–2026) CT 150 (1966–2026) OR 123 (1967–2026) IN 104 (1969–2026) NY 86 (1967–2025) KS 84 (1969–2024) PA 80 (1967–2025) IL 74 (1967–2026) VA 73 (1920–2026) WA 69 (1961–2025) GA 58 (1976–2025) NJ 54 (1967–2025) OH 53 (1968–2025) AL 50 (1947–2024) NH 48 (1983–2017) LA 45 (1969–2018) KY 44 (1968–2025) UT 44 (1988–2025) MI 43 (1966–2025) MD 39 (1962–2024) ND 38 (1964–2025) NC 38 (1971–2024) MO 37 (1958–2020) IA 37 (1974–2023) TN 32 (1970–2025) ID 32 (1970–2021) MA 31 (1967–2025) FL 31 (1936–2025) OK 29 (1962–2025) MT 27 (1971–2010) NM 27 (1967–2025) CO 25 (1970–2026) AZ 25 (1971–2021) DC 25 (1968–2022) WI 24 (1967–2026) MN 24 (1969–2024) MS 24 (1983–2012) AK 20 (1969–2026) RI 19 (1968–2008) WY 17 (1977–2019) WV 17 (1978–2025) AR 15 (1978–2018) ME 13 (1973–2025) SD 13 (1977–2022) SC 11 (1987–2025) NV 10 (1967–2022) VT 10 (1978–2015) NE 10 (1982–2023) HI 9 (1973–2024) DE 7 (1971–2022) VI 4 (2010–2015)

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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