harmless error (West Virginia) · Go Syfert
← West Virginia issues

harmless error in West Virginia

105 West Virginia opinions name it 1 courts 1893–2026 17 in the last five years

The cases below were cited by West Virginia 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 (48)

CaseFollowedCited
Chapman v. Californiared
scotus · 1967 · cited in 8 West Virginia opinions naming this issue, 1978–1997
2 sentences

1997See generally Sullivan v. Louisiana, 508 U.S. 275, 278-82 , 113 S.Ct. 2078, 2081-83 , 124 L.Ed.2d 182, 189-91 (1993) (holding the harmless error doctrine will not apply if a constitutionally deficient reasonable-doubt instruction is read to the juiy); Chapman v. California, 386 U.S. 18, 23 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705, 710 (1967), limited on other grounds Arizona v. Fulminante, 499 U.S. 279 , 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991) (recognizing "there are some constitutional rights so basic to a fair trial that their infraction can never be treated as harmless error”); Tennant v. Ma

1997See generally Sullivan v. Louisiana, 508 U.S. 275, 278-82 , 113 S.Ct. 2078, 2081-83 , 124 L.Ed.2d 182, 189-91 (1993) (holding the harmless error doctrine will not apply if a constitutionally deficient reasonable-doubt instruction is read to the juiy); Chapman v. California, 386 U.S. 18, 23 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705, 710 (1967), limited on other grounds Arizona v. Fulminante, 499 U.S. 279 , 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991) (recognizing "there are some constitutional rights so basic to a fair trial that their infraction can never be treated as harmless error”); Tennant v. Ma

48
State v. Atkinsgreen
wva · 1979 · cited in 18 West Virginia opinions naming this issue, 1980–2023
2 sentences

2023Va. 502, 511-12 , 261 S.E.2d 55, 61-62 (1979) (setting forth that where evidence is offered by a defendant but refused, the harmless error test requires weighing the prejudicial impact of the error on the jury verdict).

2016See syl. pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 446 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980) (discussing the harmless error test, where improp'ér evidence of a non-constitutional nature is introduced by the State in a criminal trial).

318
State v. Blakegreen
wva · 1996 · cited in 3 West Virginia opinions naming this issue, 1998–2024
2 sentences

2024Va. 168 , 179, 875 S.E.2d 306 , 317 (2022) (“In conducting a harmless error analysis, the inquiry is fact specific.”); see also State v. Blake, 197 W.

1998However, we believe the State is correct in its urging that a Neuman violation should be subjected to a harmless error analysis. 38 Justice Cleckley observed in State v. Blake, 197 W.Va. 700, 712 , 478 S.E.2d 550, 562 (1996), “that the rule in Neuman was merely a procedural/prophylactic rule[.]” Blake articulated that “Neuman clarified applicable procedural law only, and not substantive or constitutional law[.]” Id. 197 W.Va. at 713, 478 S.E.2d at 563 .

33
State v. Ezzellgreen
ncctapp · 2007 · cited in 3 West Virginia opinions naming this issue, 2007–2023
2 sentences

2023See also Taylor v. State, 254 Ga. App. 150 , 561 S.E.2d 833, 836 (2002) (“Even if we assume that there was an improper comment on [defendant’s] silence, such an impropriety does not automatically require reversal and may be harmless error.”); State v. Tucker, 138 Idaho 296 , 62 P.3d 644, 647 (Ct. App. 2003) (“Commentary on a defendant’s right to remain silent, if determined to be constitutional error, is subject to the harmless error analysis[.]”); State v. Ezzell, 642 S.E.2d 274, 278 (N.C.Ct.App. 2007) (“[A] comment implicating a defendant’s right to remain silent, although erroneous, is not

2008It's a reasonably close case and the Supreme Court may in fact see it differently." [7] See also Taylor v. State, 254 Ga.App. 150 , 561 S.E.2d 833, 836 (2002) ("Even if we assume that there was an improper comment on [defendant's] silence, such an impropriety does not automatically require reversal and may be harmless error."); State v. Tucker, 138 Idaho 296 , 62 P.3d 644, 647 (2003) ("Commentary on a defendant's right to remain silent, if determined to be constitutional error, is subject to the harmless error analysis[.]"); State v. Ezzell, 182 N.C.App. 417 , 642 S.E.2d 274, 278 (2007) ("[A]

33
State v. Tuckergreen
idahoctapp · 2003 · cited in 3 West Virginia opinions naming this issue, 2007–2023
2 sentences

2023See also Taylor v. State, 254 Ga. App. 150 , 561 S.E.2d 833, 836 (2002) (“Even if we assume that there was an improper comment on [defendant’s] silence, such an impropriety does not automatically require reversal and may be harmless error.”); State v. Tucker, 138 Idaho 296 , 62 P.3d 644, 647 (Ct. App. 2003) (“Commentary on a defendant’s right to remain silent, if determined to be constitutional error, is subject to the harmless error analysis[.]”); State v. Ezzell, 642 S.E.2d 274, 278 (N.C.Ct.App. 2007) (“[A] comment implicating a defendant’s right to remain silent, although erroneous, is not

2023See also Taylor v. State, 254 Ga. App. 150 , 561 S.E.2d 833, 836 (2002) (“Even if we assume that there was an improper comment on [defendant’s] silence, such an impropriety does not automatically require reversal and may be harmless error.”); State v. Tucker, 138 Idaho 296 , 62 P.3d 644, 647 (Ct. App. 2003) (“Commentary on a defendant’s right to remain silent, if determined to be constitutional error, is subject to the harmless error analysis[.]”); State v. Ezzell, 642 S.E.2d 274, 278 (N.C.Ct.App. 2007) (“[A] comment implicating a defendant’s right to remain silent, although erroneous, is not

33
Taylor v. Stategreen
gactapp · 2002 · cited in 3 West Virginia opinions naming this issue, 2007–2023
2 sentences

2023See also Taylor v. State, 254 Ga. App. 150 , 561 S.E.2d 833, 836 (2002) (“Even if we assume that there was an improper comment on [defendant’s] silence, such an impropriety does not automatically require reversal and may be harmless error.”); State v. Tucker, 138 Idaho 296 , 62 P.3d 644, 647 (Ct. App. 2003) (“Commentary on a defendant’s right to remain silent, if determined to be constitutional error, is subject to the harmless error analysis[.]”); State v. Ezzell, 642 S.E.2d 274, 278 (N.C.Ct.App. 2007) (“[A] comment implicating a defendant’s right to remain silent, although erroneous, is not

2023See also Taylor v. State, 254 Ga. App. 150 , 561 S.E.2d 833, 836 (2002) (“Even if we assume that there was an improper comment on [defendant’s] silence, such an impropriety does not automatically require reversal and may be harmless error.”); State v. Tucker, 138 Idaho 296 , 62 P.3d 644, 647 (Ct. App. 2003) (“Commentary on a defendant’s right to remain silent, if determined to be constitutional error, is subject to the harmless error analysis[.]”); State v. Ezzell, 642 S.E.2d 274, 278 (N.C.Ct.App. 2007) (“[A] comment implicating a defendant’s right to remain silent, although erroneous, is not

33
Sullivan v. Louisianagreen
scotus · 1993 · cited in 3 West Virginia opinions naming this issue, 1996–1997
2 sentences

1997See generally Sullivan v. Louisiana, 508 U.S. 275, 278-82 , 113 S.Ct. 2078, 2081-83 , 124 L.Ed.2d 182, 189-91 (1993) (holding the harmless error doctrine will not apply if a constitutionally deficient reasonable-doubt instruction is read to the juiy); Chapman v. California, 386 U.S. 18, 23 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705, 710 (1967), limited on other grounds Arizona v. Fulminante, 499 U.S. 279 , 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991) (recognizing "there are some constitutional rights so basic to a fair trial that their infraction can never be treated as harmless error”); Tennant v. Ma

1997See generally Sullivan v. Louisiana, 508 U.S. 275, 278-82 , 113 S.Ct. 2078, 2081-83 , 124 L.Ed.2d 182, 189-91 (1993) (holding the harmless error doctrine will not apply if a constitutionally deficient reasonable-doubt instruction is read to the juiy); Chapman v. California, 386 U.S. 18, 23 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705, 710 (1967), limited on other grounds Arizona v. Fulminante, 499 U.S. 279 , 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991) (recognizing "there are some constitutional rights so basic to a fair trial that their infraction can never be treated as harmless error”); Tennant v. Ma

33
State Ex Rel. Grob v. Blairgreen
wva · 1975 · cited in 6 West Virginia opinions naming this issue, 1982–2022
2 sentences

2014Grob v. Blair, 158 W.Va. 647 , 214 S.E.2d 330 (1975), explaining as follows in syllabus point five: “Failure to observe a constitutional right constitutes reversible error unless it can be shown that the error was harmless beyond a reasonable doubt.” Likewise, this Court noted in Blair: The doctrine of harmless error is firmly established by statute, court rule and decisions as a salutary aspect of the criminal law 5 of this State.

2014Grob v. Blair, 158 W.Va. 647 , 214 S.E.2d 330 (1975), explaining as follows in syllabus point five: “Failure to observe a constitutional right constitutes reversible error unless it can be shown that the error was harmless beyond a reasonable doubt.” Likewise, this Court noted in Blair: The doctrine of harmless error is firmly established by statute, court rule and decisions as a salutary aspect of the criminal law 5 of this State.

26
Delaware v. Van Arsdallgreen
scotus · 1986 · cited in 5 West Virginia opinions naming this issue, 1988–2016
2 sentences

1998In a subsequent case, Delaware v. Van Arsdall, 475 U.S. 673 , 106 S.Ct. 1431 , 89 L.Ed.2d 674 (1986), the Supreme Court examined the harmless error beyond a reasonable doubt standard in the context of a defendant’s denial of an opportunity to impeach a prosecution witness for bias and stated that a number of factors were to be considered: the importance of the witness’ testimony, whether the testimony was cumulative, the presence or absence of corroborating or contradicting testimony on material points, the extent of cross-examination otherwise permitted, and the overall strength of the prosec

1998In a subsequent case, Delaware v. Van Arsdall, 475 U.S. 673 , 106 S.Ct. 1431 , 89 L.Ed.2d 674 (1986), the Supreme Court examined the harmless error beyond a reasonable doubt standard in the context of a defendant’s denial of an opportunity to impeach a prosecution witness for bias and stated that a number of factors were to be considered: the importance of the witness’ testimony, whether the testimony was cumulative, the presence or absence of corroborating or contradicting testimony on material points, the extent of cross-examination otherwise permitted, and the overall strength of the prosec

25
State v. Valentinegreen
wva · 2001 · cited in 4 West Virginia opinions naming this issue, 2002–2026
2 sentences

2002In State v. Valentine, 208 W.Va. 513 , 541 S.E.2d 603 (2000), discussed by the dissent in support of its substantial compliance theory, this Court applied the harmless error doctrine to resolve the matter, rather than engaging in a substantial compliance deliberation.

2002In State v. Valentine, 208 W.Va. 513 , 541 S.E.2d 603 (2000), discussed by the dissent in support of its substantial compliance theory, this Court applied the harmless error doctrine to resolve the matter, rather than engaging in a substantial compliance deliberation.

24
Jones v. Stategreen
fla · 1999 · cited in 2 West Virginia opinions naming this issue, 2007–2023
2 sentences

2023This rule has been 21 applied in other jurisdictions where prosecutors have commented upon a defendant’s silence: Indeed, the general rule around the country is that “improper comments on a defendant’s invocation of his right to remain silent are subject to a harmless error analysis and need not require reversal if the Court is convinced, beyond a reasonable doubt, that the error did not contribute to the verdict.” Jones v. State, 748 So.2d 1012, 1021-1022 (Fla.1999).

2007Indeed, the general rule around the country is that "improper comments on a defendant's invocation of his right to remain silent are subject to a harmless error analysis and need not require reversal if the Court is convinced, beyond a reasonable doubt, that the error did not contribute to the verdict." Jones v. State, 748 So.2d 1012, 1021-1022 (Fla.1999).

22
State v. Shulergreen
sc · 2003 · cited in 2 West Virginia opinions naming this issue, 2007–2023
2 sentences

2023Indeed, such error will not earn the defendant a new trial if, after examining the entire record, this Court determines that the error was harmless beyond a reasonable doubt.”); State v. Shuler, 353 S.C. 176 , 577 S.E.2d 438, 444 (2003) (“While the State may not comment on the defendant’s right to remain silent, an improper reference is subject to harmless error analysis.”).

2023Indeed, such error will not earn the defendant a new trial if, after examining the entire record, this Court determines that the error was harmless beyond a reasonable doubt.”); State v. Shuler, 353 S.C. 176 , 577 S.E.2d 438, 444 (2003) (“While the State may not comment on the defendant’s right to remain silent, an improper reference is subject to harmless error analysis.”).

22
Ilosky v. Michelin Tire Corp.green
wva · 1983 · cited in 2 West Virginia opinions naming this issue, 1995–2015
2 sentences

2015See Ilosky v. Michelin Tire Corp., 172 W.Va. 435, 449 , 307 S.E.2d 603, 618 (1983) (finding that violation of the triál court’s in limine ruling was harmless error as it did not go to causation).

2015See Ilosky v. Michelin Tire Corp., 172 W.Va. 435, 449 , 307 S.E.2d 603, 618 (1983) (finding that violation of the triál court’s in limine ruling was harmless error as it did not go to causation).

22
Lee v. Illinoisgreen
scotus · 1986 · cited in 2 West Virginia opinions naming this issue, 1988–2015
2 sentences

2015See State v. Mullens, 179 W.Va. 567371 S.E.2d 64 (1988) (explaining that violation of confrontation clause is subject to harmless-error analysis (citing Lee v. Illinois, 476 U.S. 530 (1986) and Schneble v. Florida, 405 U.S. 427 (1972)); see also State v. Blevins, 231 W.Va. 135 , 744 S.E.2d 245 (2013) (confrontation clause violation was harmless beyond reasonable doubt).

1988See Lee v. Illinois, 476 U.S. at 547 , 106 S.Ct. at 2066 ; Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972). 8 .

22
State v. Pottergreen
wva · 1996 · cited in 2 West Virginia opinions naming this issue, 1998–2005
22
United States v. Hastinggreen
scotus · 1983 · cited in 2 West Virginia opinions naming this issue, 1986–1987
22
Howard v. Des Moines Register & Tribune Co.green
scotus · 1980 · cited in 10 West Virginia opinions naming this issue, 1980–2016
2 sentences

2016See syl. pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 446 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980) (discussing the harmless error test, where improp'ér evidence of a non-constitutional nature is introduced by the State in a criminal trial).

1992HARMLESS ERROR Rule 52(a) of the West Virginia Rules of Criminal Procedure provides that “[a]ny error, defect, irregularity or variance which does not affect substantial rights shall be disregarded.” The harmless error doctrine was interpreted by this Court in syllabus point 6 of State v. Smith, 178 W.Va. 104 , 358 S.E.2d 188 (1987) (quoting Syl.Pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 445 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980)) as follows: ‘Where improper evidence of a noncon-stitutional nature is introduced by the State in a criminal trial, the t

110
Murphy v. Owens-Corning Fiberglas Corp.green
scotus · 1980 · cited in 10 West Virginia opinions naming this issue, 1980–2016
2 sentences

2016See syl. pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 446 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980) (discussing the harmless error test, where improp'ér evidence of a non-constitutional nature is introduced by the State in a criminal trial).

1992HARMLESS ERROR Rule 52(a) of the West Virginia Rules of Criminal Procedure provides that “[a]ny error, defect, irregularity or variance which does not affect substantial rights shall be disregarded.” The harmless error doctrine was interpreted by this Court in syllabus point 6 of State v. Smith, 178 W.Va. 104 , 358 S.E.2d 188 (1987) (quoting Syl.Pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 445 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980)) as follows: ‘Where improper evidence of a noncon-stitutional nature is introduced by the State in a criminal trial, the t

110
Shenandoah Sales & Service, Inc. v. Assessor of Jefferson Countygreen
wva · 2012 · cited in 4 West Virginia opinions naming this issue, 2017–2023
2 sentences

2017In Shenandoah Sales & Service, Inc. v. Assessor of Jefferson County, 228 W.Va. 762, 773 , 724 S.E.2d 733, 744 (2012), we found that a failure to follow proper procedure in ruling on a motion for disqualification was subject to a harmless error analysis.

2017In Shenandoah Sales & Service, Inc. v. Assessor of Jefferson County, 228 W.Va. 762, 773 , 724 S.E.2d 733, 744 (2012), we found that a failure to follow proper procedure in ruling on a motion for disqualification was subject to a harmless error analysis.

14
State v. Boydgreen
wva · 1977 · cited in 4 West Virginia opinions naming this issue, 1979–2022
2 sentences

2022We have consistently found that a violation of the requirement that a defendant be present at all critical stages of the criminal proceeding is subject to the harmless error analysis. 21 See e.g., Syl. pt. 6, Boyd, 160 W.

1981We held in State v. Boyd, 160 W.Va. 234 , 233 S.E.2d 710 (1977) that the inalienable constitutional right cited was subject to the harmless error doctrine.

14
Robert L. Holcomb v. David Ballardgreen
wva · 2013 · cited in 2 West Virginia opinions naming this issue, 2018–2023
2 sentences

2018Petitioner’s final contention is that the circuit court’s harmless error analysis regarding any failure to duly caution him is improper and warrants reversal.1 Indeed, we held in Syllabus Point 1 of Holcomb v. Ballard, 232 W.Va. 253 , 752 S.E.2d 284 (2013) that “[t]he procedural recidivist requirements of W.Va.

2018Petitioner’s final contention is that the circuit court’s harmless error analysis regarding any failure to duly caution him is improper and warrants reversal.1 Indeed, we held in Syllabus Point 1 of Holcomb v. Ballard, 232 W.Va. 253 , 752 S.E.2d 284 (2013) that “[t]he procedural recidivist requirements of W.Va.

12
United States v. Sam T. Iaquinta, United States of America v. Velma E. Shinegreen
ca4 · 1983 · cited in 2 West Virginia opinions naming this issue, 2001–2022
2 sentences

2022Va. 125 , 488 S.E.2d 400 (1997) (holding that the harmless error test applied to Rule 11(e)(2) violations); and United States v. Iaquinta, 719 F.2d 83, 85 (4th Cir. 1983) (reversing a conviction for failure to comply with Fed.

2001Since Iaquinta, supra, was decided, several United States Courts of Appeals have adopted a harmless error analysis with respect to the omission of the Rule 11(e)(2) admonition.

12
State v. Smithgreen
wva · 1987 · cited in 2 West Virginia opinions naming this issue, 1992–2016
2 sentences

1992HARMLESS ERROR Rule 52(a) of the West Virginia Rules of Criminal Procedure provides that “[a]ny error, defect, irregularity or variance which does not affect substantial rights shall be disregarded.” The harmless error doctrine was interpreted by this Court in syllabus point 6 of State v. Smith, 178 W.Va. 104 , 358 S.E.2d 188 (1987) (quoting Syl.Pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 445 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980)) as follows: ‘Where improper evidence of a noncon-stitutional nature is introduced by the State in a criminal trial, the t

1992HARMLESS ERROR Rule 52(a) of the West Virginia Rules of Criminal Procedure provides that “[a]ny error, defect, irregularity or variance which does not affect substantial rights shall be disregarded.” The harmless error doctrine was interpreted by this Court in syllabus point 6 of State v. Smith, 178 W.Va. 104 , 358 S.E.2d 188 (1987) (quoting Syl.Pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 445 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980)) as follows: ‘Where improper evidence of a noncon-stitutional nature is introduced by the State in a criminal trial, the t

12
Schneble v. Floridagreen
scotus · 1972 · cited in 2 West Virginia opinions naming this issue, 1988–2015
2 sentences

2015See State v. Mullens, 179 W.Va. 567371 S.E.2d 64 (1988) (explaining that violation of confrontation clause is subject to harmless-error analysis (citing Lee v. Illinois, 476 U.S. 530 (1986) and Schneble v. Florida, 405 U.S. 427 (1972)); see also State v. Blevins, 231 W.Va. 135 , 744 S.E.2d 245 (2013) (confrontation clause violation was harmless beyond reasonable doubt).

1988See Lee v. Illinois, 476 U.S. at 547 , 106 S.Ct. at 2066 ; Schneble v. Florida, 405 U.S. 427 , 92 S.Ct. 1056 , 31 L.Ed.2d 340 (1972). 8 .

12
State v. Salmonsgreen
wva · 1998 · cited in 2 West Virginia opinions naming this issue, 1999–2005
2 sentences

2005Equally important, as we said in State v. Salmons, 203 W.Va. 561, 582 , 509 S.E.2d 842, 863 (1998), "[i]t defies logic for this Court to hold that a harmless error analysis applies to substantive constitutional violations, yet hold that a harmless error analysis does not apply to a prophylactic rule designed to protect enforcement of a constitutional right." In fact, "[o]ur cases consistently have held that nonconstitutional errors are harmless unless the reviewing court has grave doubt as to whether the [error] substantially swayed the verdict." State v. Potter, 197 W.Va. 734, 748 , 478 S.E.2

2005Equally important, as we said in State v. Salmons, 203 W.Va. 561, 582 , 509 S.E.2d 842, 863 (1998), "[i]t defies logic for this Court to hold that a harmless error analysis applies to substantive constitutional violations, yet hold that a harmless error analysis does not apply to a prophylactic rule designed to protect enforcement of a constitutional right." In fact, "[o]ur cases consistently have held that nonconstitutional errors are harmless unless the reviewing court has grave doubt as to whether the [error] substantially swayed the verdict." State v. Potter, 197 W.Va. 734, 748 , 478 S.E.2

12
United States v. Jabree Williamsgreen
ca3 · 2020 · cited in 1 West Virginia opinions naming this issue, 2026–2026
11
United States v. Durhamgreen
ca10 · 2018 · cited in 1 West Virginia opinions naming this issue, 2026–2026
11
United States v. Bashamgreen
ca4 · 2009 · cited in 1 West Virginia opinions naming this issue, 2026–2026
11
United States v. James Williamsgreen
ca5 · 1990 · cited in 1 West Virginia opinions naming this issue, 2026–2026
11
State v. LaRockgreen
wva · 1996 · cited in 1 West Virginia opinions naming this issue, 2026–2026
11
United States v. D.J. Coopergreen
ca4 · 2007 · cited in 1 West Virginia opinions naming this issue, 2026–2026
11
Hoffman v. Wheeling Savings & Loan Ass'ngreen
wva · 1950 · cited in 1 West Virginia opinions naming this issue, 2025–2025
11
State v. Tammy R.green
wva · 1999 · cited in 1 West Virginia opinions naming this issue, 2025–2025
11
State of West Virginia v. Roy Franklin Hillberry, IIgreen
wva · 2014 · cited in 1 West Virginia opinions naming this issue, 2023–2023
11
United States v. Williamsgreen
ca6 · 2011 · cited in 1 West Virginia opinions naming this issue, 2022–2022
11
State v. Crabtreegreen
wva · 1996 · cited in 1 West Virginia opinions naming this issue, 2017–2017
11
State of West Virginia v. Christopher Wayne Bowlinggreen
wva · 2013 · cited in 1 West Virginia opinions naming this issue, 2015–2015
11
State of West Virginia Terry Allen Blevinsgreen
wva · 2013 · cited in 1 West Virginia opinions naming this issue, 2015–2015
11
State v. Hestergreen
idaho · 1988 · cited in 1 West Virginia opinions naming this issue, 2015–2015
11
State v. Persongreen
connappct · 1989 · cited in 1 West Virginia opinions naming this issue, 2015–2015
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (32)

CaseCitedYears
Atkins v. West Virginia green
scotus · 1980
2 sentences

1992HARMLESS ERROR Rule 52(a) of the West Virginia Rules of Criminal Procedure provides that “[a]ny error, defect, irregularity or variance which does not affect substantial rights shall be disregarded.” The harmless error doctrine was interpreted by this Court in syllabus point 6 of State v. Smith, 178 W.Va. 104 , 358 S.E.2d 188 (1987) (quoting Syl.Pt. 2, State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 445 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980)) as follows: ‘Where improper evidence of a noncon-stitutional nature is introduced by the State in a criminal trial, the t

1990While the majority relies on the harmless error rule set out in Syllabus Point 2 of State v. Atkins, 163 W.Va. 502 , 261 S.E.2d 55 (1979), cert. denied, 445 U.S. 904 , 100 S.Ct. 1081 , 63 L.Ed.2d 320 (1980), it undertakes no careful analysis of the rule.

101980–2015
State Road Commission v. Bowling green
wva · 1969
2 sentences

1969Otis Bowling & Idell Bowling, decided at this term, W.Va., 166 S.E.2d 119 , the Court held: The doctrine of harmless error is firmly established by statute, court rule and court decisions as a salutary aspect of the law of this state.

1969Va. 688 , 166 S. E.2d 119 , the Court held: The doctrine of harmless error is firmly established by statute, court rule and court decisions as a salutary aspect of the law of this state.

61969–1980
State v. Thomas green
wva · 1974
2 sentences

2022Third, I wholeheartedly disagree with the court’s conclusion in Vogh that the failure to swear the jury in a criminal case, which is part and parcel of constitutional “fair trial” provisions, is subject to a harmless error analysis less rigorous than that articulated by this Court in numerous decisions: “We have long held that ‘[e]rrors involving deprivation of constitutional rights will be regarded as harmless only if there is no reasonable possibility that the violation contributed to the conviction.” Syl. pt. 20, State v. Thomas, 157 W.Va. 640 , 203 S.E.2d 445 (1974).

2022Third, I wholeheartedly disagree with the court’s conclusion in Vogh that the failure to swear the jury in a criminal case, which is part and parcel of constitutional “fair trial” provisions, is subject to a harmless error analysis less rigorous than that articulated by this Court in numerous decisions: “We have long held that ‘[e]rrors involving deprivation of constitutional rights will be regarded as harmless only if there is no reasonable possibility that the violation contributed to the conviction.” Syl. pt. 20, State v. Thomas, 157 W.Va. 640 , 203 S.E.2d 445 (1974).

41977–2022
Fahy v. Connecticut green
scotus · 1963
2 sentences

1978In devising this harmless error standard, the Court followed the approach it conceived in Fahy v. Connecticut, 375 U.S. 85 , 84 S.Ct. 229 , 11 L.Ed.2d 171 (1963), where it stated that the harmless error question must be answered by determining "whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction." 375 U.S. at 86-87 , 84 S.Ct. at 230, 11 L.Ed.2d at 173 .

1978In devising this harmless error standard, the Court followed the approach it conceived in Fahy v. Connecticut, 375 U.S. 85 , 84 S.Ct. 229 , 11 L.Ed.2d 171 (1963), where it stated that the harmless error question must be answered by determining "whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction." 375 U.S. at 86-87 , 84 S.Ct. at 230, 11 L.Ed.2d at 173 .

41978–1995
Boggs v. Settle green
wva · 1965
2 sentences

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

41969–1988
State v. Stone green
wva · 1997
2 sentences

2022Va. 125 , 488 S.E.2d 400 (1997) (holding that the harmless error test applied to Rule 11(e)(2) violations); and United States v. Iaquinta, 719 F.2d 83, 85 (4th Cir. 1983) (reversing a conviction for failure to comply with Fed.

2001Ultimately, this Court stated that "[u]nless the factual evidence is clear that no substantial rights were disregarded, the harmless error rule of Rule 11(h) [1995] [2] should not be applied." Stone, 200 W.Va. at 129 , 488 S.E.2d at 404 .

22001–2022
State v. Neuman green
wva · 1988
2 sentences

2013Consequently, we held the following in Syllabus point 15 of Salmons : A violation of State v. Neuman, 179 W.Va. 580 , 371 S.E.2d 77 (1988), is subject to a harmless error analysis.

2013Consequently, we held the following in Syllabus point 15 of Salmons : A violation of State v. Neuman, 179 W.Va. 580 , 371 S.E.2d 77 (1988), is subject to a harmless error analysis.

22000–2013
State v. Kelley green
wva · 1994
21994–1995
State v. McAboy green
wva · 1977
21979–1992
Gilland v. Commonwealth green
va · 1945
21955–1955
Katherine B. T. v. Jackson green
wva · 2006
12024–2024
State Ex Rel. Housden v. Adams green
wva · 1958
12023–2023
State v. Marple green
wva · 1996
12023–2023
State v. Lightner green
wva · 1999
12022–2022
State v. Miller green
wva · 1995
12022–2022
State v. Floray green
delsuperct · 1997
12015–2015
State v. Bradshaw green
wva · 1995
12015–2015
State v. Jenkins green
wva · 1995
12015–2015
State v. Smith green
wva · 1972
12015–2015
Baker v. Commonwealth green
ky · 1998
12015–2015
Kitts v. United States green
scotus · 2014
12015–2015
Watson v. United States green
scotus · 2014
12015–2015
Perkins v. State green
alacrimapp · 2004
12013–2013
United States v. Gonzalez-Lopez green
scotus · 2006
12010–2010
State v. Young green
wva · 1991
12005–2005
State v. Ferrell green
wva · 1990
12005–2005
In Re Burks green
wva · 1999
12002–2002
United States v. Olivia Martinez-Martinez green
ca1 · 1995
12001–2001
cluster 727993 green
ca8 · 1996
12001–2001
Taliaferro v. United States neutral
scotus · 1993
12001–2001
United States v. Rafael Noriega-Milln, A/K/A Rafi green
ca1 · 1997
12001–2001
Prescott v. Hines, Director General green
sc · 1920
12001–2001

Statutes the citing opinions construe

WV § W. Va. Code § 62-3-2 (5) WV § W. Va. Code § 61-11-18 (4) WV § W. Va. Code § 61-11-19 (4) WV § W. Va. Code § 61-8D-5 (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 1559 (1892–2026) FL 1431 (1891–2026) TX 1327 (1912–2026) PA 804 (1930–2026) LA 746 (1931–2026) IL 690 (1891–2026) WA 558 (1931–2026) OH 462 (1968–2026) WI 393 (1964–2026) AL 387 (1909–2026) MI 380 (1912–2026) TN 369 (1959–2026) KS 308 (1969–2026) IN 290 (1872–2026) NY 274 (1889–2026) VA 273 (1897–2026) CO 259 (1891–2026) ID 253 (1915–2026) NJ 241 (1900–2026) MS 239 (1968–2026) GA 237 (1903–2026) MN 229 (1940–2026) SC 225 (1977–2026) CT 225 (1970–2026) MD 212 (1961–2026) AZ 188 (1927–2026) OR 182 (1917–2026) DC 180 (1976–2026) NC 158 (1949–2026) NE 155 (1920–2025) NM 148 (1886–2026) KY 137 (1933–2026) OK 132 (1913–2024) IA 121 (1971–2026) WV 105 (1893–2026) AR 97 (1905–2026) UT 93 (1923–2025) WY 91 (1971–2025) NV 88 (1965–2026) MA 78 (1912–2025) ND 75 (1971–2025) MO 74 (1902–2023) HI 72 (1974–2026) RI 71 (1971–2026) MT 63 (1978–2026) VT 59 (1980–2026) NH 58 (1978–2026) AK 55 (1968–2020) ME 55 (1972–2026) SD 45 (1972–2026) DE 40 (1973–2025) VI 22 (2002–2017) GU 11 (2021–2025) MP 4 (1995–1996) PR 3 (1912–2025)

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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