24 Idaho opinions name it 2 courts 1981–2020 0 in the last five years
The cases below were cited by Idaho 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 |
|---|---|---|
Chapman v. Californiared2 sentences2013Under the two-part Chapman test, the defendant must establish the existence of an error, “at which point the State shall have the burden of demonstrating that the error is harmless beyond a reasonable doubt.” Id. 12 To meet that burden, the State must “prove[] ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’” Id. at 221 , 245 P.3d at 973 (quoting Chapman, 386 U.S. at 24 ). 2013Under the two-part Chapman test, the defendant must establish the existence of an error, “at which point the State shall have the burden of demonstrating that the error is harmless beyond a reasonable doubt.” Id. 12 To meet that burden, the State must “prove[] ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’” Id. at 221 , 245 P.3d at 973 (quoting Chapman, 386 U.S. at 24 ). | 2 | 11 |
State v. Perrygreen2 sentences2020We also recognized the Chapman standard as giving to the State “the burden of demonstrating to the appellate court beyond a reasonable doubt that the constitutional violation did not contribute to the jury’s verdict.” Perry, 150 Idaho at 227, 245 P.3d at 979. 2020We also recognized the Chapman standard as giving to the State “the burden of demonstrating to the appellate court beyond a reasonable doubt that the constitutional violation did not contribute to the jury’s verdict.” Perry, 150 Idaho at 227, 245 P.3d at 979. | 2 | 10 |
Sullivan v. Louisianagreen2 sentences2020Sullivan rephrased the Chapman test, under the facts of Sullivan, as the question of “whether the guilty verdict actually rendered in this trial was surely unattributable to the error.” Id. at 279 (italics in original). 2020Sullivan rephrased the Chapman test, under the facts of Sullivan, as the question of “whether the guilty verdict actually rendered in this trial was surely unattributable to the error.” Id. at 279 (italics in original). | 1 | 2 |
State v. Hector B. Almaraz, Jr.green2 sentences2020However, years later in State v. Almaraz, 154 Idaho 584, 301 P.3d 242 (2013), we cited Perry for the proposition that an “error is harmless if the Court finds that the result would be the same without the error.” Almaraz, 154 Idaho at 598, 301 P.3d at 256 (citing Perry, 150 Idaho at 227–28, 245 P.3d at 979–80). 2020However, years later in State v. Almaraz, 154 Idaho 584, 301 P.3d 242 (2013), we cited Perry for the proposition that an “error is harmless if the Court finds that the result would be the same without the error.” Almaraz, 154 Idaho at 598, 301 P.3d at 256 (citing Perry, 150 Idaho at 227–28, 245 P.3d at 979–80). | 1 | 1 |
MacDonald v. Stategreen2 sentences2012The Delaware Supreme Court held that no mistrial was necessary after a witness mentioned a previous trial because “the jury could at most only speculate as to the outcome of [defendantj’s previous trial” and “[sjuch speculation, if indeed it even occurred, would not necessarily have led the jury to believe that the trial ended in [defendantj’s conviction.” MacDonald v. State, 816 A.2d 750, 756 (Del.2003). 2012The Delaware Supreme Court held that no mistrial was necessary after a witness mentioned a previous trial because “the jury could at most only speculate as to the outcome of [defendantj’s previous trial” and “[sjuch speculation, if indeed it even occurred, would not necessarily have led the jury to believe that the trial ended in [defendantj’s conviction.” MacDonald v. State, 816 A.2d 750, 756 (Del.2003). | 1 | 1 |
People v. Boosegreen2 sentences2012In People v. Boose, 85 Ill.App.3d 457 , 40 Ill.Dec. 760 , 406 N.E.2d 963, 964-66 (1980), the Appellate Court of Illinois concluded that a witness’s “nebulous and ambiguous” references to the defendant’s incarceration and participation in an appeal were harmless under the Chapman standard. 2012In People v. Boose, 85 Ill.App.3d 457 , 40 Ill.Dec. 760 , 406 N.E.2d 963, 964-66 (1980), the Appellate Court of Illinois concluded that a witness’s “nebulous and ambiguous” references to the defendant’s incarceration and participation in an appeal were harmless under the Chapman standard. | 1 | 1 |
Harrington v. Californiared2 sentences2011But in Harrington v. California, 395 U.S. 250, 253-54 (1969), while expressly confirming that the Chapman test is appropriate, the Court held that an error was harmless because the untainted evidence of guilt was “overwhelming.” Justice Brennan, dissenting, asserted that the majority opinion thereby “shift[ed] the inquiry from whether the constitutional error contributed to the conviction to whether the untainted evidence provided ‘overwhelming’ support for the conviction” and that this approach “was expressly rejected in Chapman.” Id. at 255 . 2011But in Harrington v. California, 395 U.S. 250, 253-54 (1969), while expressly confirming that the Chapman test is appropriate, the Court held that an error was harmless because the untainted evidence of guilt was “overwhelming.” Justice Brennan, dissenting, asserted that the majority opinion thereby “shift[ed] the inquiry from whether the constitutional error contributed to the conviction to whether the untainted evidence provided ‘overwhelming’ support for the conviction” and that this approach “was expressly rejected in Chapman.” Id. at 255 . | 1 | 1 |
University of Utah Hospital Ex Rel. Harris v. Pencegreen2 sentences1996See University of Utah Hospital v. Pence, 104 Idaho 172, 176 , 657 P.2d 469, 473 (1982); LaFon v. State, 119 Idaho 387 , 807 P.2d 66 (Ct.App.1991); Mellinger v. State, 113 Idaho 31 , 740 P.2d 73 (Ct.App.1987). 1996See University of Utah Hospital v. Pence, 104 Idaho 172, 176 , 657 P.2d 469, 473 (1982); LaFon v. State, 119 Idaho 387 , 807 P.2d 66 (Ct.App.1991); Mellinger v. State, 113 Idaho 31 , 740 P.2d 73 (Ct.App.1987). | 1 | 1 |
State v. Tuckergreen2 sentences1991See State v. Tucker, 97 Idaho 4 , 539 P.2d 556 (1975). 1991See State v. Tucker, 97 Idaho 4 , 539 P.2d 556 (1975). | 1 | 1 |
State v. Wrightgreen2 sentences1983In State v. Wright, 97 Idaho 229, 231 , 542 P.2d 63, 65 (1975), our Supreme Court said, “Error in the abstract does not necessarily rise to the level of constitutional dimensions unless and until a defendant properly presents a specific prejudice resulting from such error.” Therefore, if no specific constitutional right has been violated, and there is no showing of specific prejudice infringing upon due process, appellate review of error is not subject to the Chapman test. 1983In State v. Wright, 97 Idaho 229, 231 , 542 P.2d 63, 65 (1975), our Supreme Court said, “Error in the abstract does not necessarily rise to the level of constitutional dimensions unless and until a defendant properly presents a specific prejudice resulting from such error.” Therefore, if no specific constitutional right has been violated, and there is no showing of specific prejudice infringing upon due process, appellate review of error is not subject to the Chapman test. | 1 | 1 |
State v. Sharpgreen2 sentences1981See e. g., State v. Sharp, 101 Idaho 498, 507 , 616 P.2d 1034, 1043 (1980) (Chapman rule applied to prosecutorial misconduct). 1981See e. g., State v. Sharp, 101 Idaho 498, 507 , 616 P.2d 1034, 1043 (1980) (Chapman rule applied to prosecutorial misconduct). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
United States v. Hasting
green
2 sentences2019In Hasting , the Court explained how to apply the Chapman test: "The question a reviewing court must ask is this: absent the [error], is it clear beyond a reasonable doubt that the jury would have returned a verdict of guilty?" Hasting, 461 U.S. at 510 -11 , 103 S.Ct. 1974 . 2019In Hasting , the Court explained how to apply the Chapman test: "The question a reviewing court must ask is this: absent the [error], is it clear beyond a reasonable doubt that the jury would have returned a verdict of guilty?" Hasting, 461 U.S. at 510 -11 , 103 S.Ct. 1974 . | 3 | 2019–2019 |
Neder v. United States
green
2 sentences2019The United States Supreme Court applied the Chapman standard in Neder v. United States, 527 U.S. 1 (1999). 2019The United States Supreme Court applied the Chapman standard in Neder v. United States, 527 U.S. 1 (1999). | 1 | 2019–2019 |
Deck v. Missouri
green
2 sentences2012In such a circumstance, the State must prove “beyond a reasonable doubt that the [shackling] error complained of did not contribute to the verdict obtained.” Id. (quoting Chapman, 386 *488 U.S. at 24, 87 S.Ct. at 828 , 17 L.Ed.2d at 711 ; see also State v. Perry, 150 Idaho 209, 227 , 245 P.3d 961, 979 (2010) (adopting the Chapman test for harmless error). 2012In such a circumstance, the State must prove “beyond a reasonable doubt that the [shackling] error complained of did not contribute to the verdict obtained.” Id. (quoting Chapman, 386 *488 U.S. at 24, 87 S.Ct. at 828 , 17 L.Ed.2d at 711 ; see also State v. Perry, 150 Idaho 209, 227 , 245 P.3d 961, 979 (2010) (adopting the Chapman test for harmless error). | 1 | 2012–2012 |
Satterwhite v. Texas
green
2 sentences2011In Satterwhite v. Texas, 486 U.S. 249 (1988), the Supreme Court stated that the Chapman test is not “whether the legally admitted evidence was sufficient to support” a conviction but “whether the State has proved ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict.’” Id. at 258 (quoting Chapman, 386 U.S. at 24 ). 2011In Satterwhite v. Texas, 486 U.S. 249 (1988), the Supreme Court stated that the Chapman test is not “whether the legally admitted evidence was sufficient to support” a conviction but “whether the State has proved ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict.’” Id. at 258 (quoting Chapman, 386 U.S. at 24 ). | 1 | 2011–2011 |
State v. Anderson
green
2 sentences2010We recognize that, in addition to holding that the state failed to satisfy the Chapman test, the Court in Anderson also held that it could not “conclude beyond a reasonable doubt that the jury would have reached the same conclusion had it faced all of the statutory elements.” Anderson, 144 Idaho at 749 , 170 P.3d at 892 .4 We need not now decide 4 We note that previous Idaho appellate decisions have applied the same harmless error test applied in Anderson. 2010We recognize that, in addition to holding that the state failed to satisfy the Chapman test, the Court in Anderson also held that it could not “conclude beyond a reasonable doubt that the jury would have reached the same conclusion had it faced all of the statutory elements.” Anderson, 144 Idaho at 749 , 170 P.3d at 892 .4 We need not now decide 4 We note that previous Idaho appellate decisions have applied the same harmless error test applied in Anderson. | 1 | 2010–2010 |
Mellinger v. State
green
2 sentences1996See University of Utah Hospital v. Pence, 104 Idaho 172, 176 , 657 P.2d 469, 473 (1982); LaFon v. State, 119 Idaho 387 , 807 P.2d 66 (Ct.App.1991); Mellinger v. State, 113 Idaho 31 , 740 P.2d 73 (Ct.App.1987). 1996See University of Utah Hospital v. Pence, 104 Idaho 172, 176 , 657 P.2d 469, 473 (1982); LaFon v. State, 119 Idaho 387 , 807 P.2d 66 (Ct.App.1991); Mellinger v. State, 113 Idaho 31 , 740 P.2d 73 (Ct.App.1987). | 1 | 1996–1996 |
LaFon v. State
green
2 sentences1996See University of Utah Hospital v. Pence, 104 Idaho 172, 176 , 657 P.2d 469, 473 (1982); LaFon v. State, 119 Idaho 387 , 807 P.2d 66 (Ct.App.1991); Mellinger v. State, 113 Idaho 31 , 740 P.2d 73 (Ct.App.1987). 1996See University of Utah Hospital v. Pence, 104 Idaho 172, 176 , 657 P.2d 469, 473 (1982); LaFon v. State, 119 Idaho 387 , 807 P.2d 66 (Ct.App.1991); Mellinger v. State, 113 Idaho 31 , 740 P.2d 73 (Ct.App.1987). | 1 | 1996–1996 |
State v. Chapman
green
2 sentences1994The issue on appeal, as framed by the Supreme Court, was “Did the district court have jurisdiction to grant Chapman’s motion?” 121 Idaho at 352 , 825 P.2d at 75 . 1994The issue on appeal, as framed by the Supreme Court, was “Did the district court have jurisdiction to grant Chapman’s motion?” 121 Idaho at 352 , 825 P.2d at 75 . | 1 | 1994–1994 |
State v. Edwards
green
2 sentences1985Bistline, J., the author of LePage, supra, wrote separately to clarify the Chapman standard: If the Arizona Supreme Court and other state courts are obligated to, and do, apply the Chapman [v. California, 386 U.S. 18 [ 87 S.Ct. 824 , 17 L.Ed.2d 705 ] (1967) ] rule, then this Court, too, “before a federal constitutional error can be held harmless, must be able to declare a belief that it was harmless beyond a reasonable doubt.” This in turn does not mean that this Court can speculate what a jury might have done absent the constitutional error committed, but rather requires “the beneficiary of a 1985Bistline, J., the author of LePage, supra, wrote separately to clarify the Chapman standard: If the Arizona Supreme Court and other state courts are obligated to, and do, apply the Chapman [v. California, 386 U.S. 18 [ 87 S.Ct. 824 , 17 L.Ed.2d 705 ] (1967) ] rule, then this Court, too, “before a federal constitutional error can be held harmless, must be able to declare a belief that it was harmless beyond a reasonable doubt.” This in turn does not mean that this Court can speculate what a jury might have done absent the constitutional error committed, but rather requires “the beneficiary of a | 1 | 1985–1985 |
Fahy v. Connecticut
green
2 sentences1985Bistline, J., the author of LePage, supra, wrote separately to clarify the Chapman standard: If the Arizona Supreme Court and other state courts are obligated to, and do, apply the Chapman [v. California, 386 U.S. 18 [ 87 S.Ct. 824 , 17 L.Ed.2d 705 ] (1967) ] rule, then this Court, too, “before a federal constitutional error can be held harmless, must be able to declare a belief that it was harmless beyond a reasonable doubt.” This in turn does not mean that this Court can speculate what a jury might have done absent the constitutional error committed, but rather requires “the beneficiary of a 1985Bistline, J., the author of LePage, supra, wrote separately to clarify the Chapman standard: If the Arizona Supreme Court and other state courts are obligated to, and do, apply the Chapman [v. California, 386 U.S. 18 [ 87 S.Ct. 824 , 17 L.Ed.2d 705 ] (1967) ] rule, then this Court, too, “before a federal constitutional error can be held harmless, must be able to declare a belief that it was harmless beyond a reasonable doubt.” This in turn does not mean that this Court can speculate what a jury might have done absent the constitutional error committed, but rather requires “the beneficiary of a | 1 | 1985–1985 |
New York Times Co. v. Sullivan
green
2 sentences1981Since Chapman it is necessary to envision “harmless error” as not restricted to meaning error that is merely not prejudicial, but also to envision “harmless error” as error which, though prejudicial, does not amount to reversible error, viewed within the Chapman rule. *398 Similarly, since New York Times Co. v. Sullivan, 376 U.S. 254 , 84 S.Ct. 710 , 11 L.Ed.2d 686 (1964), it has become necessary to think not only in terms of malice, actual and implied, but in terms of constitutional malice. 1981Since Chapman it is necessary to envision “harmless error” as not restricted to meaning error that is merely not prejudicial, but also to envision “harmless error” as error which, though prejudicial, does not amount to reversible error, viewed within the Chapman rule. *398 Similarly, since New York Times Co. v. Sullivan, 376 U.S. 254 , 84 S.Ct. 710 , 11 L.Ed.2d 686 (1964), it has become necessary to think not only in terms of malice, actual and implied, but in terms of constitutional malice. | 1 | 1981–1981 |
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.