unless error (North Carolina) · Go Syfert
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unless error in North Carolina

24 North Carolina opinions name it 2 courts 1903–2026 3 in the last five years

The cases below were cited by North Carolina 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 (10)

CaseFollowedCited
Word v. Jones Ex Rel. Mooregreen
nc · 1999 · cited in 3 North Carolina opinions naming this issue, 2007–2015
2 sentences

2015P. 61; see also Word v. Jones, -15- 350 N.C. 557, 565 , 516 S.E.2d 144, 148 (1999) (holding that “erroneous jury instructions are not grounds for granting a new trial unless the error affected a substantial right”).

2015P. 61; see also Word v. Jones, -15- 350 N.C. 557, 565 , 516 S.E.2d 144, 148 (1999) (holding that “erroneous jury instructions are not grounds for granting a new trial unless the error affected a substantial right”).

23
State v. Russellgreen
ncctapp · 1989 · cited in 2 North Carolina opinions naming this issue, 2003–2008
2 sentences

2008“Error committed at trial infringing upon one’s constitutional rights is presumed to be prejudicial and entitles [defendant] to a new trial unless the error was harmless beyond a reasonable doubt.” State v. Russell, 92 N.C.

2003“Error committed at trial infringing upon one’s constitutional rights is presumed to be prejudicial and entitles him to a new trial unless the error was harmless beyond a reasonable doubt.” State v. Russell, 92 N.C.

22
State v. Autrygreen
nc · 1988 · cited in 3 North Carolina opinions naming this issue, 1989–2023
2 sentences

2023RICHARDSON Earls, J., concurring in part and dissenting in part 1223(e), and he was required to disclose his knowledge of the prosecution and the Richardson family either to the parties in this case or a neutral arbiter under the Eighth Amendment to the U.S. Constitution. “[E]rror committed at trial which infringes upon [a] defendant’s constitutional rights is presumed to be prejudicial and entitles him to a new trial unless the error in question is harmless beyond a reasonable doubt.” State v. Autry, 321 N.C. 392 , 399–400 (1988).

2023RICHARDSON Earls, J., concurring in part and dissenting in part 1223(e), and he was required to disclose his knowledge of the prosecution and the Richardson family either to the parties in this case or a neutral arbiter under the Eighth Amendment to the U.S. Constitution. “[E]rror committed at trial which infringes upon [a] defendant’s constitutional rights is presumed to be prejudicial and entitles him to a new trial unless the error in question is harmless beyond a reasonable doubt.” State v. Autry, 321 N.C. 392 , 399–400 (1988).

13
State v. Alstongreen
nc · 1983 · cited in 2 North Carolina opinions naming this issue, 2001–2009
2 sentences

2009Alston, 307 N.C. at 339-40 , 298 S.E.2d at 644 .

2009Alston, 307 N.C. at 339-40 , 298 S.E.2d at 644 .

12
State v. Wilkersongreen
nc · 2009 · cited in 1 North Carolina opinions naming this issue, 2026–2026
2 sentences

2026See State v. Wilkerson, 363 N.C. 382, 415 , 683 S.E.2d 174, 194 (2009) (citations omitted).

2026See State v. Wilkerson, 363 N.C. 382, 415 , 683 S.E.2d 174, 194 (2009) (citations omitted).

11
State v. Cookgreen
ncctapp · 2008 · cited in 1 North Carolina opinions naming this issue, 2016–2016
2 sentences

2016See State v. Cook , 193 N.C.App. 179 , 185, 666 S.E.2d 795 , 799 (2008) (citation omitted).

2016See State v. Cook , 193 N.C.App. 179 , 185, 666 S.E.2d 795 , 799 (2008) (citation omitted).

11
State v. Soyarsgreen
nc · 1992 · cited in 1 North Carolina opinions naming this issue, 2008–2008
2 sentences

2008App. 639, 644 , 376 S.E.2d 458, 461 (1989). “[T]he question is whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” State v. Soyars, 332 N.C. 47, 58 , 418 S.E.2d 480, 487 (1992).

2008App. 639, 644 , 376 S.E.2d 458, 461 (1989). “[T]he question is whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” State v. Soyars, 332 N.C. 47, 58 , 418 S.E.2d 480, 487 (1992).

11
United States v. Milton L. McCaskillgreen
ca4 · 1982 · cited in 1 North Carolina opinions naming this issue, 1990–1990
1 sentence

1990Even though the admission of the statements constitutes trial error, this error will not mandate a new trial unless the error constitutes “plain error.” The “plain error” rule is “always to be applied cautiously and only in the exceptional case where, after reviewing the entire record, it can be said that the claimed error is a ‘fundamental error, something so basic, so prejudicial, so lacking in its elements that justice cannot have been done[.]’ ” State v. Odom, 307 N.C. 655, 660 , 300 S.E.2d 375, 378 (1983), quoting United States v. McCaskill, 676 F.2d 995, 1002 (4th Cir.), cert. denied, 45

11
State v. Odomgreen
nc · 1983 · cited in 1 North Carolina opinions naming this issue, 1990–1990
2 sentences

1990Even though the admission of the statements constitutes trial error, this error will not mandate a new trial unless the error constitutes “plain error.” The “plain error” rule is “always to be applied cautiously and only in the exceptional case where, after reviewing the entire record, it can be said that the claimed error is a ‘fundamental error, something so basic, so prejudicial, so lacking in its elements that justice cannot have been done[.]’ ” State v. Odom, 307 N.C. 655, 660 , 300 S.E.2d 375, 378 (1983), quoting United States v. McCaskill, 676 F.2d 995, 1002 (4th Cir.), cert. denied, 45

1990Even though the admission of the statements constitutes trial error, this error will not mandate a new trial unless the error constitutes “plain error.” The “plain error” rule is “always to be applied cautiously and only in the exceptional case where, after reviewing the entire record, it can be said that the claimed error is a ‘fundamental error, something so basic, so prejudicial, so lacking in its elements that justice cannot have been done[.]’ ” State v. Odom, 307 N.C. 655, 660 , 300 S.E.2d 375, 378 (1983), quoting United States v. McCaskill, 676 F.2d 995, 1002 (4th Cir.), cert. denied, 45

11
Moore v. Illinoisgreen
scotus · 1977 · cited in 1 North Carolina opinions naming this issue, 1982–1982
2 sentences

1982G.S. 15A-1443(b); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); see Moore v. Illinois, 434 U.S. 220 , 98 S.Ct. 458 , 54 L.Ed.2d 424 (1977); Milton v. Wainwright, 407 U.S. 371 , 92 S.Ct. 2174 , 33 L.Ed.2d 1 (1972); Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972).

1982G.S. 15A-1443(b); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); see Moore v. Illinois, 434 U.S. 220 , 98 S.Ct. 458 , 54 L.Ed.2d 424 (1977); Milton v. Wainwright, 407 U.S. 371 , 92 S.Ct. 2174 , 33 L.Ed.2d 1 (1972); Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (15)

CaseCitedYears
State v. Brown green
nc · 1982
2 sentences

1997Because the error is of constitutional dimensions it is “presumed to be prejudicial” and entitles the defendant “to a new trial unless the error committed was harmless beyond a reasonable doubt.” State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 74 L.

1997Because the error is of constitutional dimensions it is “presumed to be prejudicial” and entitles the defendant “to a new trial unless the error committed was harmless beyond a reasonable doubt.” State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 74 L.

51988–1997
In re Davis green
scotus · 1982
2 sentences

1997Because the error is of constitutional dimensions it is “presumed to be prejudicial” and entitles the defendant “to a new trial unless the error committed was harmless beyond a reasonable doubt.” State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 74 L.

1992“Error committed at trial infringing, upon a defendant’s constitutional rights is presumed to be prejudicial and entitles him to a new trial unless the error committed was harmless beyond a reasonable doubt.” State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 74 L.

31992–1997
Otey v. Nebraska green
scotus · 1982
2 sentences

1997Because the error is of constitutional dimensions it is “presumed to be prejudicial” and entitles the defendant “to a new trial unless the error committed was harmless beyond a reasonable doubt.” State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 74 L.

1992“Error committed at trial infringing, upon a defendant’s constitutional rights is presumed to be prejudicial and entitles him to a new trial unless the error committed was harmless beyond a reasonable doubt.” State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 74 L.

31992–1997
Chapman v. California red
scotus · 1967
2 sentences

1992N.C.G.S. § 15A-1443(b) (1988); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 103 S.Ct. 503 , 74 L.Ed.2d 642 (1982).

1992N.C.G.S. § 15A-1443(b) (1988); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); State v. Brown, 306 N.C. 151, 164 , 293 S.E.2d 569, 578 , cert. denied, 459 U.S. 1080 , 103 S.Ct. 503 , 74 L.Ed.2d 642 (1982).

21982–1992
Tucker v. . Satterthwaite neutral
· 1897
2 sentences

1955In the case of Tucker v. Satter-thwaite, 120 N.C. 118 , 27 S.E. 45, 46 , it does not appear that an exception was entered to the issues submitted; nevertheless, this Court said: "We are not inadvertent to the long line of decisions laying down the rule that the refusal of the court to submit an issue tendered by either party cannot be reviewed by this court unless exception is taken in apt time; nor do we wish to be understood as reversing or modifying it.

1955In the case of Tucker v. Satter-thwaite, 120 N.C. 118 , 27 S.E. 45, 46 , it does not appear that an exception was entered to the issues submitted; nevertheless, this Court said: "We are not inadvertent to the long line of decisions laying down the rule that the refusal of the court to submit an issue tendered by either party cannot be reviewed by this court unless exception is taken in apt time; nor do we wish to be understood as reversing or modifying it.

21903–1955
State v. Mendoza green
ncctapp · 2016
1 sentence

2019App. ----, ----, 794 S.E.2d 828 , 834 (2016).

12019–2019
Dean v. United States green
scotus · 1982
1 sentence

1990Even though the admission of the statements constitutes trial error, this error will not mandate a new trial unless the error constitutes “plain error.” The “plain error” rule is “always to be applied cautiously and only in the exceptional case where, after reviewing the entire record, it can be said that the claimed error is a ‘fundamental error, something so basic, so prejudicial, so lacking in its elements that justice cannot have been done[.]’ ” State v. Odom, 307 N.C. 655, 660 , 300 S.E.2d 375, 378 (1983), quoting United States v. McCaskill, 676 F.2d 995, 1002 (4th Cir.), cert. denied, 45

11990–1990
McCoy v. Bordenkircher green
scotus · 1982
1 sentence

1990Even though the admission of the statements constitutes trial error, this error will not mandate a new trial unless the error constitutes “plain error.” The “plain error” rule is “always to be applied cautiously and only in the exceptional case where, after reviewing the entire record, it can be said that the claimed error is a ‘fundamental error, something so basic, so prejudicial, so lacking in its elements that justice cannot have been done[.]’ ” State v. Odom, 307 N.C. 655, 660 , 300 S.E.2d 375, 378 (1983), quoting United States v. McCaskill, 676 F.2d 995, 1002 (4th Cir.), cert. denied, 45

11990–1990
Milton v. Wainwright green
scotus · 1972
2 sentences

1982G.S. 15A-1443(b); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); see Moore v. Illinois, 434 U.S. 220 , 98 S.Ct. 458 , 54 L.Ed.2d 424 (1977); Milton v. Wainwright, 407 U.S. 371 , 92 S.Ct. 2174 , 33 L.Ed.2d 1 (1972); Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972).

1982G.S. 15A-1443(b); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); see Moore v. Illinois, 434 U.S. 220 , 98 S.Ct. 458 , 54 L.Ed.2d 424 (1977); Milton v. Wainwright, 407 U.S. 371 , 92 S.Ct. 2174 , 33 L.Ed.2d 1 (1972); Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972).

11982–1982
Schneble v. Florida green
scotus · 1972
2 sentences

1982G.S. 15A-1443(b); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); see Moore v. Illinois, 434 U.S. 220 , 98 S.Ct. 458 , 54 L.Ed.2d 424 (1977); Milton v. Wainwright, 407 U.S. 371 , 92 S.Ct. 2174 , 33 L.Ed.2d 1 (1972); Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972).

1982G.S. 15A-1443(b); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967); see Moore v. Illinois, 434 U.S. 220 , 98 S.Ct. 458 , 54 L.Ed.2d 424 (1977); Milton v. Wainwright, 407 U.S. 371 , 92 S.Ct. 2174 , 33 L.Ed.2d 1 (1972); Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972).

11982–1982
State v. Turner green
nc · 1966
2 sentences

1973State v. Turner, 268 N.C. 225 , 150 S.E. 2d 406 ; State v. Rainey, 236 N.C. 738 , 74 S.E. 2d 39 .

1973State v. Turner, 268 N.C. 225 , 150 S.E. 2d 406 ; State v. Rainey, 236 N.C. 738 , 74 S.E. 2d 39 .

11973–1973
State v. Rainey green
nc · 1953
2 sentences

1973State v. Turner, 268 N.C. 225 , 150 S.E. 2d 406 ; State v. Rainey, 236 N.C. 738 , 74 S.E. 2d 39 .

1973State v. Turner, 268 N.C. 225 , 150 S.E. 2d 406 ; State v. Rainey, 236 N.C. 738 , 74 S.E. 2d 39 .

11973–1973
Jenkins v. North Carolina Ore Dressing Co. green
nc · 1871
1 sentence

1905Reade, J., in Jenkins v. Ore Dressing Co., 65 N. C., 563 , says: “It is difficult to lay down tbe line, further than to say, that it must ordinarily be left to the discretion of the judge who tries the cause; and this court will not review his discretion unless it is apparent that the impropriety of counsel was gross, and well calculated to prejudice the jury.” It is settled by this court that unless exception is taken, either at the time the language is usted, or by request to the court to instruct the jury that they must disregard the objectionable language it cannot be assigned as error.

11905–1905
State v. . Tyson green
nc · 1903
1 sentence

1905The cases are collected and discussed in State v. Tyson, 133 N. C., 692 .

11905–1905
Pearce v. Fisher. neutral
nc · 1903
2 sentences

1903As said by Mr. Justice Douglas in Tucker v. Satterthwaite, 120 N. C., 118 , “We are not inadvertent to the long line of decisions laying down the rule that the refusal of the Court to submit an issue tendered by either party cannot be reviewed by this Court unless exception is taken in apt time; nor do we wish to be understood as reversing* or modifying it. * * * What we now say is that section 395 of the Code is mandatory, binding equally upon the Court and upon counsel; that it is the duty of the Judge, either of his own motion or at the suggestion of counsel, to submit such issues as are ne

1903What we now say is that section 395 of the Code is mandatory, binding equally upon the court and upon counsel; that it is the duty of the judge, either of his own motion or at the suggestion of counsel, to submit such issues as are necessary to settle the material controversies arising in the pleadings, and that in the absence of such issues or admissions of record equivalent thereto sufficient to reasonably justify, directly or by clear *Page 76 implication, the judgment rendered therein, this Court will remand the case for a new trial." In Pearce v. Fisher , at this term, 133 N.C. 333 , two

11903–1903

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 15A-1443 (14) NC § N.C. Gen. Stat. § 8C-1 (9) NC § N.C. Gen. Stat. § 15A-2000 (7) NC § N.C. Gen. Stat. § 14-17 (3) NC § N.C. Gen. Stat. § 15A-903 (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

NM 53 (2010–2026) WV 48 (1949–2026) MN 38 (1986–2026) NC 24 (1903–2026) OK 16 (1925–2007) MI 15 (1994–2026) WA 13 (1973–2022) PA 12 (1969–2014) TX 12 (1911–2020) TN 10 (2002–2021) MO 9 (1898–2009) NY 9 (1976–2016) MA 8 (1973–2021) IL 6 (1989–2025) CA 5 (1955–2022) MD 5 (1975–2007) NJ 4 (2019–2022) WI 4 (1908–2012) CO 3 (2004–2019) LA 3 (1965–1988) MT 3 (1931–2004) KS 3 (1896–1976) GA 3 (1990–2016) CT 3 (1935–1974) NV 2 (1973–2022) IN 2 (1947–1999) OH 2 (1999–2022) FL 2 (1965–1968) OR 2 (1998–2012)

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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