federal constitutional error (Oregon) · Go Syfert
← Oregon issues

federal constitutional error in Oregon

123 Oregon opinions name it 3 courts 1967–2026 36 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.

Followed or applied (33)

CaseFollowedCited
Sterling v. Cuppgreen
or · 1981 · cited in 25 Oregon opinions naming this issue, 1992–2025
2 sentences

2025Sterling v. Cupp, 290 Or 611, 614 , 625 P2d 123 (1981) (“The proper sequence is to analyze the state’s law, including its constitutional law, before reaching a federal constitutional claim.”).

2025Sterling v. Cupp, 290 Or 611, 614 , 625 P2d 123 (1981) (“The proper sequence is to analyze the state’s law, including its constitutional law, before reaching a federal constitutional claim.”).

1825
State v. Perkinsgreen
orctapp · 2023 · cited in 13 Oregon opinions naming this issue, 2023–2025
2 sentences

2025Because “the failure to submit a required 616 State v. Breslin element of an offense to the jury is a federal constitutional error,” “to affirm, we must be able to conclude that the error is harmless beyond a reasonable doubt.” State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023).

2025Because “the failure to submit a required 616 State v. Breslin element of an offense to the jury is a federal constitutional error,” “to affirm, we must be able to conclude that the error is harmless beyond a reasonable doubt.” State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023).

413
Chapman v. Californiared
scotus · 1967 · cited in 22 Oregon opinions naming this issue, 1967–2026
2 sentences

2026Similarly, a federal constitutional error is harmless, such that the conviction will be upheld, “if the reviewing court may confidently say, on the whole record, that the con- stitutional error was harmless beyond a reasonable doubt.” Delaware v. Van Arsdall, 475 US 673, 681 , 106 S Ct 1431 , 89 L Ed 2d 674 (1986) (describing the test announced in Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967)).

2026Similarly, a federal constitutional error is harmless, such that the conviction will be upheld, “if the reviewing court may confidently say, on the whole record, that the con- stitutional error was harmless beyond a reasonable doubt.” Delaware v. Van Arsdall, 475 US 673, 681 , 106 S Ct 1431 , 89 L Ed 2d 674 (1986) (describing the test announced in Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967)).

322
Delaware v. Van Arsdallgreen
scotus · 1986 · cited in 17 Oregon opinions naming this issue, 2006–2026
2 sentences

2026Similarly, a federal constitutional error is harmless, such that the conviction will be upheld, “if the reviewing court may confidently say, on the whole record, that the con- stitutional error was harmless beyond a reasonable doubt.” Delaware v. Van Arsdall, 475 US 673, 681 , 106 S Ct 1431 , 89 L Ed 2d 674 (1986) (describing the test announced in Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967)).

2026Similarly, a federal constitutional error is harmless, such that the conviction will be upheld, “if the reviewing court may confidently say, on the whole record, that the con- stitutional error was harmless beyond a reasonable doubt.” Delaware v. Van Arsdall, 475 US 673, 681 , 106 S Ct 1431 , 89 L Ed 2d 674 (1986) (describing the test announced in Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967)).

217
State v. Cookgreen
or · 2006 · cited in 9 Oregon opinions naming this issue, 2006–2024
2 sentences

2024See State v. Cook, 340 Or App 530 , 544, 135 P3d 260 (2006) (concluding that a federal constitutional error does not require reversal if the constitutional error was harm- less beyond a reasonable doubt); see also State v. Johnson, 329 Or App 588, 634 , 542 P3d 467 (2023) (citing Washington v. Recuenco, 548 US 212 , 126 S Ct 2546 , 165 L Ed 2d 466 (2006) for the proposition that an Apprendi federal consti- tutional violation is not structural error and is subject to harmless error analysis).

2014As noted, defendant asserts that the trial court’s denial of the motion to reset deprived him of certain federal constitutional rights, specifically the rights to “ [h] ave [c]ounsel [c]onduct an [a]dequate [investigation, to a [flair trial and to [d]ue [p]rocess.” “A federal constitutional error is harmless, such that the conviction will be upheld, ‘if the reviewing court may confidently say, on the whole record, that the constitutional error was harmless beyond a reasonable doubt.’” State v. Cook, 340 Or 530, 544 , 135 P3d 260 (2006) (quoting Delaware v. Van Arsdall, 475 US 673, 681 , 106 S

29
State v. Waterhousegreen
or · 2016 · cited in 2 Oregon opinions naming this issue, 2025–2025
2 sentences

2025As relevant here, a person commits third-degree theft when, among other requirements, the “total value of the property * * * is less than $100.” ORS 164.043(1)(b); see also State v. Waterhouse, 359 Or 351, 362 , 373 P3d 131 (2016) (explaining that the “value range” of third-degree theft “falls essentially between some value greater than zero but less than $100”).

2025As relevant here, a person commits third-degree theft when, among other requirements, the “total value of the property * * * is less than $100.” ORS 164.043(1)(b); see also State v. Waterhouse, 359 Or 351, 362 , 373 P3d 131 (2016) (explaining that the “value range” of third-degree theft “falls essentially between some value greater than zero but less than $100”).

22
State v. Inmangreen
orctapp · 2015 · cited in 2 Oregon opinions naming this issue, 2023–2023
2 sentences

2023The likelihood that the error affected the outcome goes to its “gravity” and to “the ends of justice.” Inman, 275 Or App at 936 (“[T]he error in to submit a required element of an offense to the jury is a federal constitutional error” and that the federal harmlessness standard requires that “the error is harmless beyond a reasonable doubt.” Defendant in the present case has not claimed a federal constitutional violation, instead arguing only under the state constitutional harmlessness standard.

2023The likelihood that the error affected the outcome goes to its “gravity” and to “the ends of justice.” Inman, 275 Or App at 936 (“[T]he error in to submit a required element of an offense to the jury is a federal constitutional error” and that the federal harmlessness standard requires that “the error is harmless beyond a reasonable doubt.” Defendant in the present case has not claimed a federal constitutional violation, instead arguing only under the state constitutional harmlessness standard.

22
State v. Mendezgreen
or · 1989 · cited in 2 Oregon opinions naming this issue, 2003–2010
2 sentences

2010See State v. Mendez, 308 Or 9, 19 , 774 P2d 1082 (1989) (limiting discussion to the defendant’s federal constitutional claim where he “failed to brief or argue any independent state constitutional theory’). 6 In Christoff erson, the plaintiff had become a member of the Church of Scientology and paid for and participated in various courses and activities promoted by the church. 57 Or App at 207-08 .

2010See State v. Mendez, 308 Or 9, 19 , 774 P2d 1082 (1989) (limiting discussion to the defendant’s federal constitutional claim where he “failed to brief or argue any independent state constitutional theory’). 6 In Christoff erson, the plaintiff had become a member of the Church of Scientology and paid for and participated in various courses and activities promoted by the church. 57 Or App at 207-08 .

22
Arizona v. Fulminantegreen
scotus · 1991 · cited in 3 Oregon opinions naming this issue, 1993–2021
2 sentences

2021Flores Ramos, 367 Or at 533 (“When a federal constitutional error is not structural, the conviction can be affirmed only if the error ‘was harmless beyond a reasonable doubt.’ ” (Quoting Arizona v. Fulminante, 499 US 279, 307-08 , 111 S Ct 1246 , 113 L Ed 2d 302 (1991).)).

2021Flores Ramos, 367 Or at 533 (“When a federal constitutional error is not structural, the conviction can be affirmed only if the error ‘was harmless beyond a reasonable doubt.’ ” (Quoting Arizona v. Fulminante, 499 US 279, 307-08 , 111 S Ct 1246 , 113 L Ed 2d 302 (1991).)).

13
State v. Owengreen
or · 2022 · cited in 2 Oregon opinions naming this issue, 2024–2025
2 sentences

2024State v. Owen, 369 Or 288, 323 , 505 P3d 953 (2022). 1 In State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023), which involved a preserved error, we explained that the failure to submit a required element of the offense is harmless under the federal constitutional standard if the state proves beyond a reasonable doubt that the error did not contribute to the verdict.

2024State v. Owen, 369 Or 288, 323 , 505 P3d 953 (2022). 1 In State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023), which involved a preserved error, we explained that the failure to submit a required element of the offense is harmless under the federal constitutional standard if the state proves beyond a reasonable doubt that the error did not contribute to the verdict.

12
State v. Davisgreen
or · 2003 · cited in 2 Oregon opinions naming this issue, 2009–2024
2 sentences

2024See State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (an error is harmless, and thus not a basis for reversal, where there is “little likelihood that the error affected the jury’s verdict”); State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (a federal constitutional error is harmless, and thus not a basis for reversal, if the state proves beyond a reasonable doubt that the error did not contribute to the verdict).2 We are unpersuaded that the error was harmless.

2024See State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (an error is harmless, and thus not a basis for reversal, where there is “little likelihood that the error affected the jury’s verdict”); State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (a federal constitutional error is harmless, and thus not a basis for reversal, if the state proves beyond a reasonable doubt that the error did not contribute to the verdict).2 We are unpersuaded that the error was harmless.

12
State v. Osborngreen
orctapp · 2021 · cited in 1 Oregon opinions naming this issue, 2025–2025
2 sentences

2025See State v. Osborn, 315 Or App 102 , 500 P3d 61 (2021) (recog- nizing that when there is a federal constitutional violation “the state bears the burden to demonstrate that the error is harmless beyond a reasonable doubt.”); accord Chapman v. California, 386 US 18 , 87 S Ct 824 , 17 L Ed 2d 705 (1967). 278 State v. Rodriguez state has not met its burden to demonstrate that defendant made a constitutionally sufficient waiver of his Article I, sec- tion 12, rights.

2025See State v. Osborn, 315 Or App 102 , 500 P3d 61 (2021) (recog- nizing that when there is a federal constitutional violation “the state bears the burden to demonstrate that the error is harmless beyond a reasonable doubt.”); accord Chapman v. California, 386 US 18 , 87 S Ct 824 , 17 L Ed 2d 705 (1967). 278 State v. Rodriguez state has not met its burden to demonstrate that defendant made a constitutionally sufficient waiver of his Article I, sec- tion 12, rights.

11
Twentieth Century-Fox Film Corp. v. Department of Revenuegreen
or · 1985 · cited in 1 Oregon opinions naming this issue, 2025–2025
1 sentence

2025(See, e.g., Ptf’s Memo Further Supp Mot Summ J at 25; Ptf’s Memo Mot Summ J at 19-20 (quoting Twentieth Century-Fox, 299 Or at 228 (statute applies “in unusual cases” where UDITPA formula does not fairly represent taxpayer’s business activity).) This court reads Twentieth Century-Fox, as well as statements of the UDITPA framers when taken in their greater context, as expressing an expectation that the standard formulas under UDITPA will likely yield a fair result in most cases, not as prescribing an additional element of “unusualness” that is AMENDED ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

11
Washington v. Recuencogreen
scotus · 2006 · cited in 1 Oregon opinions naming this issue, 2024–2024
2 sentences

2024See State v. Cook, 340 Or App 530 , 544, 135 P3d 260 (2006) (concluding that a federal constitutional error does not require reversal if the constitutional error was harm- less beyond a reasonable doubt); see also State v. Johnson, 329 Or App 588, 634 , 542 P3d 467 (2023) (citing Washington v. Recuenco, 548 US 212 , 126 S Ct 2546 , 165 L Ed 2d 466 (2006) for the proposition that an Apprendi federal consti- tutional violation is not structural error and is subject to harmless error analysis).

2024See State v. Cook, 340 Or App 530 , 544, 135 P3d 260 (2006) (concluding that a federal constitutional error does not require reversal if the constitutional error was harm- less beyond a reasonable doubt); see also State v. Johnson, 329 Or App 588, 634 , 542 P3d 467 (2023) (citing Washington v. Recuenco, 548 US 212 , 126 S Ct 2546 , 165 L Ed 2d 466 (2006) for the proposition that an Apprendi federal consti- tutional violation is not structural error and is subject to harmless error analysis).

11
State v. Johnsongreen
orctapp · 2023 · cited in 1 Oregon opinions naming this issue, 2024–2024
2 sentences

2024See State v. Cook, 340 Or App 530 , 544, 135 P3d 260 (2006) (concluding that a federal constitutional error does not require reversal if the constitutional error was harm- less beyond a reasonable doubt); see also State v. Johnson, 329 Or App 588, 634 , 542 P3d 467 (2023) (citing Washington v. Recuenco, 548 US 212 , 126 S Ct 2546 , 165 L Ed 2d 466 (2006) for the proposition that an Apprendi federal consti- tutional violation is not structural error and is subject to harmless error analysis).

2024See State v. Cook, 340 Or App 530 , 544, 135 P3d 260 (2006) (concluding that a federal constitutional error does not require reversal if the constitutional error was harm- less beyond a reasonable doubt); see also State v. Johnson, 329 Or App 588, 634 , 542 P3d 467 (2023) (citing Washington v. Recuenco, 548 US 212 , 126 S Ct 2546 , 165 L Ed 2d 466 (2006) for the proposition that an Apprendi federal consti- tutional violation is not structural error and is subject to harmless error analysis).

11
Hill v. Lockhartgreen
scotus · 1985 · cited in 1 Oregon opinions naming this issue, 2023–2023
2 sentences

2023See, e.g., Hill v. Lockhart, 474 US 52, 58-59 , 106 S Ct 366 (1985) (observing that “[i]n the context of guilty pleas,” the prejudice prong under the federal constitutional standard requires the peti- tioner to “show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial”); Moen v. Peterson, 312 Or 503, 512-13 , 824 P2d 404 (1991) (adopting Hill’s prej- udice standard to the Oregon constitutional standard).

2023See, e.g., Hill v. Lockhart, 474 US 52, 58-59 , 106 S Ct 366 (1985) (observing that “[i]n the context of guilty pleas,” the prejudice prong under the federal constitutional standard requires the peti- tioner to “show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial”); Moen v. Peterson, 312 Or 503, 512-13 , 824 P2d 404 (1991) (adopting Hill’s prej- udice standard to the Oregon constitutional standard).

11
Washington v. Glucksberggreen
scotus · 1997 · cited in 1 Oregon opinions naming this issue, 2022–2022
2 sentences

2022See Washington v. Glucksberg, 521 US 702, 710 , 117 S Ct 2258 , 138 L Ed 2d 772 (1997) (“We begin, as we do in all due process cases, by examining our Nation’s history, legal traditions, and practices.”).

2022See Washington v. Glucksberg, 521 US 702, 710 , 117 S Ct 2258 , 138 L Ed 2d 772 (1997) (“We begin, as we do in all due process cases, by examining our Nation’s history, legal traditions, and practices.”).

11
Brown v. Allengreen
scotus · 1953 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
State v. Flores Ramosgreen
or · 2020 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
Montez v. Czerniakgreen
or · 2014 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
State v. Tragergreen
orctapp · 1999 · cited in 1 Oregon opinions naming this issue, 2019–2019
11
State v. Martingreen
or · 1978 · cited in 1 Oregon opinions naming this issue, 2018–2018
11
People v. Millergreen
colo · 2005 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
United States v. Olanogreen
scotus · 1993 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
State v. Kellgreen
or · 1987 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
State v. Shaffgreen
or · 2007 · cited in 1 Oregon opinions naming this issue, 2015–2015
11
State v. Probstgreen
or · 2005 · cited in 1 Oregon opinions naming this issue, 2014–2014
11
Christofferson v. CHURCH OF SCIENTOLOGY, ETC.green
orctapp · 1982 · cited in 1 Oregon opinions naming this issue, 2010–2010
11
O'Neill v. O'Neillgreen
or · 1976 · cited in 1 Oregon opinions naming this issue, 2006–2006
11
Eugene Sand & Gravel, Inc. v. City of Eugenegreen
or · 1976 · cited in 1 Oregon opinions naming this issue, 2006–2006
11
Lowe v. Eugene Sand & Gravel, Inc.green
scotus · 1977 · cited in 1 Oregon opinions naming this issue, 2006–2006
11
Keenan v. Matthewsgreen
· 1914 · cited in 1 Oregon opinions naming this issue, 2006–2006
11
Ailes v. Portland Meadows, Inc.green
or · 1991 · cited in 1 Oregon opinions naming this issue, 2004–2004
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (47)

CaseCitedYears
State v. Kennedy green
or · 1983
2 sentences

1993See Sterling v. Cupp, 290 Or. 611, 614 , 625 P.2d 123 (1981) ("[t]he proper sequence is to analyze the state's law, including its constitutional law, before reaching a federal constitutional claim"); State v. Kennedy, 295 Or. 260, 262 , 666 P.2d 1316 (1983) (stating methodology).

1993See Sterling v. Cupp, 290 Or. 611, 614 , 625 P.2d 123 (1981) ("[t]he proper sequence is to analyze the state's law, including its constitutional law, before reaching a federal constitutional claim"); State v. Kennedy, 295 Or. 260, 262 , 666 P.2d 1316 (1983) (stating methodology).

51986–2009
Neder v. United States green
scotus · 1999
2 sentences

2025Because the failure to submit a required element of an offense to the jury is a federal constitutional error, “[t]he test ‘is whether it appears beyond a reasonable doubt that the error com- plained of did not contribute to the verdict obtained.’ ” State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (quoting Neder v. United States, 527 US 1, 15 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999)).

2025Because the failure to submit a required element of an offense to the jury is a federal constitutional error, “[t]he test ‘is whether it appears beyond a reasonable doubt that the error com- plained of did not contribute to the verdict obtained.’ ” State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (quoting Neder v. United States, 527 US 1, 15 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999)).

42023–2025
State v. Horton green
orctapp · 2023
2 sentences

2025Further, even when we have concluded that the failure to give such an instruction did not meet the standard for harmless error, we have declined to exercise discretion to correct the error where the likelihood that it affected the jury’s verdict was “extremely low.” See State v. Horton, 327 Or App 256, 266 , 535 P3d 338 (2023) (declining to exercise discretion to cor- rect plainly erroneous lack of mental state instruction, even though the error was not legally harmless, because of the “extremely low likelihood” that error affected the verdict).

2025Further, even when we have concluded that the failure to give such an instruction did not meet the standard for harmless error, we have declined to exercise discretion to correct the error where the likelihood that it affected the jury’s verdict was “extremely low.” See State v. Horton, 327 Or App 256, 266 , 535 P3d 338 (2023) (declining to exercise discretion to cor- rect plainly erroneous lack of mental state instruction, even though the error was not legally harmless, because of the “extremely low likelihood” that error affected the verdict).

32023–2025
State v. Fleetwood green
orctapp · 2026
2 sentences

2026In reviewing the whole record to determine whether an error was harmless, we consider “the impor- tance of the [improperly admitted evidence] in the prosecu- tion’s case, whether the [evidence] was cumulative, the pres- ence or absence of evidence corroborating or contradicting the [improperly admitted evidence] on material points, the extent of cross-examination otherwise permitted, and, of Cite as 347 Or App 594 (2026) 605 course, the overall strength of the prosecution’s case.” Id. at 684 .

2026In reviewing the whole record to determine whether an error was harmless, we consider “the impor- tance of the [improperly admitted evidence] in the prosecu- tion’s case, whether the [evidence] was cumulative, the pres- ence or absence of evidence corroborating or contradicting the [improperly admitted evidence] on material points, the extent of cross-examination otherwise permitted, and, of Cite as 347 Or App 594 (2026) 605 course, the overall strength of the prosecution’s case.” Id. at 684 .

22026–2026
State v. Sanchez neutral
orctapp · 2025
2 sentences

2025Cite as 344 Or App 85 (2025) 89 a per se exigency justifying an exception to the Fourth Amendment’s warrant requirement.

2025Cite as 344 Or App 85 (2025) 89 a per se exigency justifying an exception to the Fourth Amendment’s warrant requirement.

22025–2025
Smith v. Arizona green
scotus · 2024
2 sentences

2025In reviewing the whole record to determine whether an error was harmless, we consider “the impor- tance of the [improperly admitted evidence] in the prosecu- tion’s case, whether the [evidence] was cumulative, the pres- ence or absence of evidence corroborating or contradicting the [improperly admitted evidence] on material points, the 1 Defendant’s argument is similar to the one the defendant raised in Smith v. Arizona, 602 US 779 , 144 S Ct 1785 , 219 L Ed 2d 420 (2024), a recent United States Supreme Court case addressing Confrontation Clause limitations on the admission of evidence.

2025In reviewing the whole record to determine whether an error was harmless, we consider “the impor- tance of the [improperly admitted evidence] in the prosecu- tion’s case, whether the [evidence] was cumulative, the pres- ence or absence of evidence corroborating or contradicting the [improperly admitted evidence] on material points, the 1 Defendant’s argument is similar to the one the defendant raised in Smith v. Arizona, 602 US 779 , 144 S Ct 1785 , 219 L Ed 2d 420 (2024), a recent United States Supreme Court case addressing Confrontation Clause limitations on the admission of evidence.

22025–2025
State v. Copeland green
or · 2013
2 sentences

2025Article I, section 11, of the Oregon Constitution guarantees a criminal defendant the right to confront and cross-examine adverse witnesses.12 State v. Copeland, 353 Or 816, 827-28 , 306 P3d 610 (2013).

2025Article I, section 11, of the Oregon Constitution guarantees a criminal defendant the right to confront and cross-examine adverse witnesses.12 State v. Copeland, 353 Or 816, 827-28 , 306 P3d 610 (2013).

22025–2025
Estelle v. McGuire green
scotus · 1991
2 sentences

1993Luce v. United States, 469 U.S. 38, 42-43 , 105 S.Ct. 460, 463-464 , 83 L.Ed.2d 443 (1984). [10] See Arizona v. Fulminante, 499 U.S. ___ , ___, 111 S.Ct. 1246, 1263-65 , 113 L.Ed.2d 302, 329-31 (1991), compiling cases in which the Supreme Court of the United States has applied the harmless error analysis to errors in the trial process, but distinguishing errors involving "structural defects in the constitution of the trial mechanism, which defy analysis by `harmless-error' standards." Where the harmless error inquiry is applied to direct appeals, the Supreme Court of the United States articula

1993Luce v. United States, 469 U.S. 38, 42-43 , 105 S.Ct. 460, 463-464 , 83 L.Ed.2d 443 (1984). [10] See Arizona v. Fulminante, 499 U.S. ___ , ___, 111 S.Ct. 1246, 1263-65 , 113 L.Ed.2d 302, 329-31 (1991), compiling cases in which the Supreme Court of the United States has applied the harmless error analysis to errors in the trial process, but distinguishing errors involving "structural defects in the constitution of the trial mechanism, which defy analysis by `harmless-error' standards." Where the harmless error inquiry is applied to direct appeals, the Supreme Court of the United States articula

21992–1993
Seymour v. United States green
scotus · 1967
2 sentences

1991In that case, before the error may be found harmless, the state must prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained. “[Bjefore a federal constitutional error can be held harmless, the court must be able to declare a belief that the error was harmless beyond a reasonable doubt.” Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 , reh’g den 386 US 987 (1967); see Rose v. Clark, 478 US 570, 576 , 106 S Ct 3101 , 92 L Ed 2d 460 (1986) (an otherwise valid conviction should not be set aside if the reviewing court may confiden

1991In that case, before the error may be found harmless, the state must prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained. "[B]efore a federal constitutional error can be held harmless, the court must be able to declare a belief that the error was harmless beyond a reasonable doubt." Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 828 , 17 L.Ed.2d 705 , reh'g den. 386 U.S. 987 , 87 S.Ct. 1283 , 18 L.Ed.2d 241 (1967); see Rose v. Clark, 478 U.S. 570, 576 , 106 S.Ct. 3101, 3105 , 92 L.Ed.2d 460 (1986) (an otherwise valid conviction should

21979–1991
State v. Stilling green
or · 1979
2 sentences

1982Because a federal constitutional error is at issue, we may affirm the conviction, despite error, only if we are “ ‘able to declare a belief that [the error] was harmless beyond a reasonable doubt.’ ” State v. Stilling, 285 Or 293, 304 , 590 P2d 1223 , cert den 444 US 880 (1979) (quoting Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967)).

1982Because a federal constitutional error is at issue, we may affirm the conviction, despite error, only if we are “ ‘able to declare a belief that [the error] was harmless beyond a reasonable doubt.’ ” State v. Stilling, 285 Or 293, 304 , 590 P2d 1223 , cert den 444 US 880 (1979) (quoting Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967)).

21982–1985
Jersey Central Power & Light Co. v. Federal Energy Regulatory Commission green
scotus · 1979
2 sentences

1985Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967); State v. Stilling, 285 Or 293, 304 , 590 P2d 1223 , cert den 444 US 880 (1979).

1982Because a federal constitutional error is at issue, we may affirm the conviction, despite error, only if we are “ ‘able to declare a belief that [the error] was harmless beyond a reasonable doubt.’ ” State v. Stilling, 285 Or 293, 304 , 590 P2d 1223 , cert den 444 US 880 (1979) (quoting Chapman v. California, 386 US 18, 24 , 87 S Ct 824 , 17 L Ed 2d 705 (1967)).

21982–1985
State v. Baker green
orctapp · 2023
1 sentence

2024This case is similar to Perkins, 325 Or App at 632 , which involved a stolen U-Haul van, and State v. Baker, 325 Or App 367, 370-71 , 528 P3d 2 It is unclear whether defendant is claiming an error of state law, subject to state-law harmlessness analysis, or a federal constitutional error, subject to federal-law harmlessness analysis.

12024–2024
Moen v. Peterson green
or · 1991
2 sentences

2023See, e.g., Hill v. Lockhart, 474 US 52, 58-59 , 106 S Ct 366 (1985) (observing that “[i]n the context of guilty pleas,” the prejudice prong under the federal constitutional standard requires the peti- tioner to “show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial”); Moen v. Peterson, 312 Or 503, 512-13 , 824 P2d 404 (1991) (adopting Hill’s prej- udice standard to the Oregon constitutional standard).

2023See, e.g., Hill v. Lockhart, 474 US 52, 58-59 , 106 S Ct 366 (1985) (observing that “[i]n the context of guilty pleas,” the prejudice prong under the federal constitutional standard requires the peti- tioner to “show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial”); Moen v. Peterson, 312 Or 503, 512-13 , 824 P2d 404 (1991) (adopting Hill’s prej- udice standard to the Oregon constitutional standard).

12023–2023
Waley v. Johnston green
scotus · 1942
12021–2021
State v. Ward green
or · 2020
12020–2020
Graham v. Florida green
scotus · 2010
12019–2019
Robinson v. California green
scotus · 1962
12019–2019
Schlup v. Delo red
scotus · 1995
12018–2018
Crawford v. Washington green
scotus · 2004
12017–2017
State v. MacK green
or · 2004
12017–2017
Edwards v. Arizona green
scotus · 1981
12016–2016
Alabama v. Smith green
scotus · 1989
12016–2016
North Carolina v. Pearce red
scotus · 1969
12016–2016
State v. Partain green
or · 2010
12016–2016
State v. Vazquez-Escobar green
orctapp · 2007
12016–2016
People v. Carines green
mich · 1999
12016–2016
State v. Brumbach green
orctapp · 2015
12016–2016
California v. Carney green
scotus · 1985
12015–2015
State v. Davis green
or · 1983
12015–2015
Carroll v. United States green
scotus · 1925
12015–2015
State v. Mosley neutral
orctapp · 2001
12015–2015
State v. Bridewell green
or · 1988
12015–2015
Chambers v. Maroney green
scotus · 1970
12015–2015
State v. Johnson green
orctapp · 2001
12015–2015
Ayala v. Hall green
or · 2008
12014–2014
State v. Ashbaugh green
or · 2010
12014–2014
Outdoor Media Dimensions Inc. v. State green
or · 2001
12014–2014
State v. Bowen green
orctapp · 2008
12014–2014
State v. Backstrand green
or · 2013
12014–2014
State v. Bailey green
or · 2014
12014–2014

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 161.085 (12) OR § Or. Rev. Stat. § 163.427 (12) OR § Or. Rev. Stat. § 813.010 (8) OR § Or. Rev. Stat. § 163.115 (6) OR § Or. Rev. Stat. § 163.375 (6) OR § Or. Rev. Stat. § 163.405 (6) OR § Or. Rev. Stat. § 164.225 (6) OR § Or. Rev. Stat. § 166.270 (6) OR § Or. Rev. Stat. § 811.140 (6) OR § Or. Rev. Stat. § 163.411 (5) OR § Or. Rev. Stat. § 174.010 (5) OR § Or. Rev. Stat. § 162.315 (4)

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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