doctrines of plain error (Utah) · Go Syfert
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doctrines of plain error in Utah

15 Utah opinions name it 2 courts 2002–2023 1 in the last five years

The cases below were cited by Utah 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
State v. Dunngreen
utah · 1993 · cited in 5 Utah opinions naming this issue, 2002–2019
2 sentences

2017We conclude that, although the prejudice from any single error is elusive when viewed solely through the doctrines of plain error and ineffective assistance of counsel, “the cumulative effect of the several errors undermines our confidence that a fair trial was had.” Cf. State v. Dunn, 850 P.2d 1201, 1229 (Utah 1993) (ellipsis, citation, and internal quotation marks omitted).

2017We conclude that, although the prejudice from any single error is elusive when viewed solely through the doctrines of plain error and ineffective assistance of counsel, “the cumulative effect of the several errors undermines our confidence that a fair trial was had.” Cf. State v. Dunn, 850 P.2d 1201, 1229 (Utah 1993) (ellipsis, citation, and internal quotation marks omitted).

45
State v. Emmettgreen
utah · 1992 · cited in 2 Utah opinions naming this issue, 2002–2010
2 sentences

2010A. Plain Error ¶ 27 King's "failure to object to improper remarks" waives his prosecutorial misconduct claim unless the remarks reach the level of plain error, State v. Emmett, 839 P.2d 781, 785 (Utah 1992), meaning that "an error exists [that] should have been obvious to the trial court" and that "the error was harmful," State v. Dunn, 850 P.2d 1201, 1208-09 (Utah 1993).

2002To obtain reversal under these doe-trines, Terril must show either (1) that the prosecutor's comments were so obviously improper that the trial court had an opportunity to address the error, see Emmett, 839 P.2d at 785 ; State v. Dunn, 850 P.2d 1201, 1208 (Utah 1993), or (2) that in failing to object to the prosecutor's remarks, his counsel's performance "fell below an objective standard of reasonable professional judgment," State v. Chacon, 962 P.2d 48, 50 (Utah 1998).

12
State v. Callihamgreen
utah · 2002 · cited in 1 Utah opinions naming this issue, 2014–2014
2 sentences

2014See State v. Calliham, 2002 UT 86, ¶ 62 , 55 P.3d 573 .

2014See State v. Calliham, 2002 UT 86, ¶ 62 , 55 P.3d 573 .

11
State v. Sellersgreen
utahctapp · 2011 · cited in 1 Utah opinions naming this issue, 2013–2013
2 sentences

2013See Sellers, 2011 UT App 38, ¶¶ 7-9 , 248 P.3d 70 .

2013See Sellers, 2011 UT App 38, ¶¶ 7-9 , 248 P.3d 70 .

11
State v. Cramgreen
utah · 2002 · cited in 1 Utah opinions naming this issue, 2013–2013
2 sentences

2013See generally State v. Cram, 2002 UT 37, ¶ 4 , 46 P.3d 230 (listing plain error, exceptional circumstances, and ineffective assistance of counsel as exceptions to the preservation rule).

2013See generally State v. Cram, 2002 UT 37, ¶ 4 , 46 P.3d 230 (listing plain error, exceptional circumstances, and ineffective assistance of counsel as exceptions to the preservation rule).

11
State v. Troygreen
utah · 1984 · cited in 1 Utah opinions naming this issue, 2002–2002
1 sentence

2002Improper remarks will be deemed harmful if the jury was, "under the cireumstances of the particular case, probably influenced by those remarks." State v. Troy, 688 P.2d 483, 486 (Utah 1984) (quoting State v. Valdes, 30 Utah 2d 54, 60 , 513 P.2d 422, 426 (1973)); see also State v. Kohl, 2000 UT 35, ¶ 22 , 999 P.2d 7 (stating prosecutor's statements harmful if they manifest error that " 'is substantial and prejudicial such that *594 there is a reasonable likelihood that, in its absence, there would have been a more favorable result.'" (quoting State v. Longshaw, 961 P.2d 925, 928 (Utah Ct.App.19

11
State v. Longshawgreen
utahctapp · 1998 · cited in 1 Utah opinions naming this issue, 2002–2002
1 sentence

2002Improper remarks will be deemed harmful if the jury was, "under the cireumstances of the particular case, probably influenced by those remarks." State v. Troy, 688 P.2d 483, 486 (Utah 1984) (quoting State v. Valdes, 30 Utah 2d 54, 60 , 513 P.2d 422, 426 (1973)); see also State v. Kohl, 2000 UT 35, ¶ 22 , 999 P.2d 7 (stating prosecutor's statements harmful if they manifest error that " 'is substantial and prejudicial such that *594 there is a reasonable likelihood that, in its absence, there would have been a more favorable result.'" (quoting State v. Longshaw, 961 P.2d 925, 928 (Utah Ct.App.19

11
State v. Kohlgreen
utah · 2000 · cited in 1 Utah opinions naming this issue, 2002–2002
2 sentences

2002Improper remarks will be deemed harmful if the jury was, "under the cireumstances of the particular case, probably influenced by those remarks." State v. Troy, 688 P.2d 483, 486 (Utah 1984) (quoting State v. Valdes, 30 Utah 2d 54, 60 , 513 P.2d 422, 426 (1973)); see also State v. Kohl, 2000 UT 35, ¶ 22 , 999 P.2d 7 (stating prosecutor's statements harmful if they manifest error that " 'is substantial and prejudicial such that *594 there is a reasonable likelihood that, in its absence, there would have been a more favorable result.'" (quoting State v. Longshaw, 961 P.2d 925, 928 (Utah Ct.App.19

2002Improper remarks will be deemed harmful if the jury was, "under the cireumstances of the particular case, probably influenced by those remarks." State v. Troy, 688 P.2d 483, 486 (Utah 1984) (quoting State v. Valdes, 30 Utah 2d 54, 60 , 513 P.2d 422, 426 (1973)); see also State v. Kohl, 2000 UT 35, ¶ 22 , 999 P.2d 7 (stating prosecutor's statements harmful if they manifest error that " 'is substantial and prejudicial such that *594 there is a reasonable likelihood that, in its absence, there would have been a more favorable result.'" (quoting State v. Longshaw, 961 P.2d 925, 928 (Utah Ct.App.19

11
State v. Chacongreen
utah · 1998 · cited in 1 Utah opinions naming this issue, 2002–2002
1 sentence

2002To obtain reversal under these doe-trines, Terril must show either (1) that the prosecutor's comments were so obviously improper that the trial court had an opportunity to address the error, see Emmett, 839 P.2d at 785 ; State v. Dunn, 850 P.2d 1201, 1208 (Utah 1993), or (2) that in failing to object to the prosecutor's remarks, his counsel's performance "fell below an objective standard of reasonable professional judgment," State v. Chacon, 962 P.2d 48, 50 (Utah 1998).

11
State v. Valdezgreen
utah · 1973 · cited in 1 Utah opinions naming this issue, 2002–2002
2 sentences

2002Improper remarks will be deemed harmful if the jury was, "under the cireumstances of the particular case, probably influenced by those remarks." State v. Troy, 688 P.2d 483, 486 (Utah 1984) (quoting State v. Valdes, 30 Utah 2d 54, 60 , 513 P.2d 422, 426 (1973)); see also State v. Kohl, 2000 UT 35, ¶ 22 , 999 P.2d 7 (stating prosecutor's statements harmful if they manifest error that " 'is substantial and prejudicial such that *594 there is a reasonable likelihood that, in its absence, there would have been a more favorable result.'" (quoting State v. Longshaw, 961 P.2d 925, 928 (Utah Ct.App.19

2002Improper remarks will be deemed harmful if the jury was, "under the cireumstances of the particular case, probably influenced by those remarks." State v. Troy, 688 P.2d 483, 486 (Utah 1984) (quoting State v. Valdes, 30 Utah 2d 54, 60 , 513 P.2d 422, 426 (1973)); see also State v. Kohl, 2000 UT 35, ¶ 22 , 999 P.2d 7 (stating prosecutor's statements harmful if they manifest error that " 'is substantial and prejudicial such that *594 there is a reasonable likelihood that, in its absence, there would have been a more favorable result.'" (quoting State v. Longshaw, 961 P.2d 925, 928 (Utah Ct.App.19

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
State v. Griffin green
utah · 2016
2 sentences

2017State v. Holgate, 2000 UT 74, ¶ 13 , 10 P.3d 346 (plain error); State v. Griffin, 2016 UT 33, ¶ 22 , 384 P.3d 186 (ineffective assistance of counsel). ¶29 Other rules of preservation or waiver are set forth in the rules of procedure promulgated by this court.

2017State v. Holgate, 2000 UT 74, ¶ 13 , 10 P.3d 346 (plain error); State v. Griffin, 2016 UT 33, ¶ 22 , 384 P.3d 186 (ineffective assistance of counsel). ¶29 Other rules of preservation or waiver are set forth in the rules of procedure promulgated by this court.

32017–2017
State v. Holgate green
utah · 2000
2 sentences

2017State v. Holgate, 2000 UT 74, ¶ 13 , 10 P.3d 346 (plain error); State v. Griffin, 2016 UT 33, ¶ 22 , 384 P.3d 186 (ineffective assistance of counsel). ¶29 Other rules of preservation or waiver are set forth in the rules of procedure promulgated by this court.

2017State v. Holgate, 2000 UT 74, ¶ 13 , 10 P.3d 346 (plain error); State v. Griffin, 2016 UT 33, ¶ 22 , 384 P.3d 186 (ineffective assistance of counsel). ¶29 Other rules of preservation or waiver are set forth in the rules of procedure promulgated by this court.

32017–2017
State v. Low green
utah · 2008
2 sentences

2013"When a party fails to preserve an issue for appeal, we will address the issue only if (1) the appellant establishes that the district court committed plain error, (2) exceptional cireumstances exist, or (3) in some situations, if the appellant raises a claim of ineffective assistance of counsel in failing to preserve the issue." State v. Low, 2008 UT 58, ¶ 19 , 192 P.3d 867 (citations and internal quotation marks omitted). 113 McNeil also asserts the hearsay and best evidence claims under the doctrines of plain error and ineffective assistance of counsel.

2013"When a party fails to preserve an issue for appeal, we will address the issue only if (1) the appellant establishes that the district court committed plain error, (2) exceptional cireumstances exist, or (3) in some situations, if the appellant raises a claim of ineffective assistance of counsel in failing to preserve the issue." State v. Low, 2008 UT 58, ¶ 19 , 192 P.3d 867 (citations and internal quotation marks omitted). 113 McNeil also asserts the hearsay and best evidence claims under the doctrines of plain error and ineffective assistance of counsel.

22012–2013
State v. Maestas green
utah · 2012
2 sentences

2023“In considering an insufficiency of the evidence claim, we review the evidence and all inferences which may reasonably be drawn from it in the light most favorable to the verdict of the jury.” State v. Maestas, 2012 UT 46, ¶ 302 , 299 P.3d 892 (cleaned up).

2023“In considering an insufficiency of the evidence claim, we review the evidence and all inferences which may reasonably be drawn from it in the light most favorable to the verdict of the jury.” State v. Maestas, 2012 UT 46, ¶ 302 , 299 P.3d 892 (cleaned up).

12023–2023
State v. Malaga green
utahctapp · 2006
1 sentence

2023However, when a defendant fails to preserve an assertion of erroneous jury instructions, we “address purported errors made in the jury instructions under the doctrines of plain error/manifest injustice, exceptional circumstances, or ineffective assistance of counsel.” See id. ¶25 Fourth, Johnson claims that his convictions were not supported by substantial evidence.

12023–2023
State v. Johnson green
utah · 2017
2 sentences

2019Defense counsel did not request these remedies at trial, and Roberts asks us to review this unpreserved issue under the doctrines of plain error and ineffective assistance of counsel. 3 See State v. Johnson , 2017 UT 76 , ¶ 19, 416 P.3d 443 (explaining that plain error and ineffective assistance of counsel are exceptions to the preservation requirement).

2019Defense counsel did not request these remedies at trial, and Roberts asks us to review this unpreserved issue under the doctrines of plain error and ineffective assistance of counsel. 3 See State v. Johnson , 2017 UT 76 , ¶ 19, 416 P.3d 443 (explaining that plain error and ineffective assistance of counsel are exceptions to the preservation requirement).

12019–2019
State v. Martinez-Castellanos green
utahctapp · 2017
1 sentence

2017We therefore vacate Martinez-Castellanos’ convictions and remand for a new trial. 20130432-CA 14 2017 UT App 13 State v. Martinez-Castellanos I.

12017–2017
State v. Welborn green
utahctapp · 2012
2 sentences

2012In reviewing a trial court's decision for plain error, we consider "whether ') [aln error exists; (M) the error should have been obvious to the trial court; and (#) the error is harmful" " See State v. Welborn, 2012 UT App 5, ¶ 4 , 268 P.3d 881 (mem.) (alteration in original) (quoting State v. Dunn, 850 P.2d 1201, 1208 (Utah 1993)).

2012In reviewing a trial court's decision for plain error, we consider "whether ') [aln error exists; (M) the error should have been obvious to the trial court; and (#) the error is harmful" " See State v. Welborn, 2012 UT App 5, ¶ 4 , 268 P.3d 881 (mem.) (alteration in original) (quoting State v. Dunn, 850 P.2d 1201, 1208 (Utah 1993)).

12012–2012
State v. Weaver green
utah · 2005
2 sentences

2012State v. Low, 2008 UT 58, ¶ 19 , 192 P.3d 867 (quoting State v. Weaver, 2005 UT 49, ¶ 18 , 122 P.3d 566 ; State v. Hansen, 2002 UT 114 , ¶ 21 n. 2, 61 P.3d 1062 ). 114 Sessions asks us to address his claims under the doctrines of plain error and ineffective assistance of counsel.

2012State v. Low, 2008 UT 58, ¶ 19 , 192 P.3d 867 (quoting State v. Weaver, 2005 UT 49, ¶ 18 , 122 P.3d 566 ; State v. Hansen, 2002 UT 114 , ¶ 21 n. 2, 61 P.3d 1062 ). 114 Sessions asks us to address his claims under the doctrines of plain error and ineffective assistance of counsel.

12012–2012
State v. Hansen green
utah · 2002
2 sentences

2012State v. Low, 2008 UT 58, ¶ 19 , 192 P.3d 867 (quoting State v. Weaver, 2005 UT 49, ¶ 18 , 122 P.3d 566 ; State v. Hansen, 2002 UT 114 , ¶ 21 n. 2, 61 P.3d 1062 ). 114 Sessions asks us to address his claims under the doctrines of plain error and ineffective assistance of counsel.

2012State v. Low, 2008 UT 58, ¶ 19 , 192 P.3d 867 (quoting State v. Weaver, 2005 UT 49, ¶ 18 , 122 P.3d 566 ; State v. Hansen, 2002 UT 114 , ¶ 21 n. 2, 61 P.3d 1062 ). 114 Sessions asks us to address his claims under the doctrines of plain error and ineffective assistance of counsel.

12012–2012
State v. Parker green
utah · 2000
2 sentences

2007Under the plain error doctrine, we will reverse the trial court's ruling only if "`(i) [a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome for [the defendant].'" State v. Hassan, 2004 UT 99, ¶ 10 , 108 P.3d 695 (quoting State v. Parker, 2000 UT 51, ¶ 7 , 4 P.3d 778 ).

2007Under the plain error doctrine, we will reverse the trial court's ruling only if "`(i) [a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome for [the defendant].'" State v. Hassan, 2004 UT 99, ¶ 10 , 108 P.3d 695 (quoting State v. Parker, 2000 UT 51, ¶ 7 , 4 P.3d 778 ).

12007–2007
State v. Hassan green
utah · 2004
2 sentences

2007Under the plain error doctrine, we will reverse the trial court's ruling only if "`(i) [a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome for [the defendant].'" State v. Hassan, 2004 UT 99, ¶ 10 , 108 P.3d 695 (quoting State v. Parker, 2000 UT 51, ¶ 7 , 4 P.3d 778 ).

2007Under the plain error doctrine, we will reverse the trial court's ruling only if "`(i) [a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome for [the defendant].'" State v. Hassan, 2004 UT 99, ¶ 10 , 108 P.3d 695 (quoting State v. Parker, 2000 UT 51, ¶ 7 , 4 P.3d 778 ).

12007–2007

Statutes the citing opinions construe

UT § Utah Code § 77-13-1 (3) UT § Utah Code § 77-13-6 (3) UT § Utah Code § 78A-4-103 (3) UT § Utah Code § 78A-7-106 (3) UT § Utah Code § 78B-3-201 (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

UT 15 (2002–2023) IL 2 (2021–2021)

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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