mere technical error (Missouri) · Go Syfert
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mere technical error in Missouri

14 Missouri opinions name it 2 courts 1952–2024 2 in the last five years

The cases below were cited by Missouri 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
Yagovane v. Stategreen
moctapp · 1996 · cited in 3 Missouri opinions naming this issue, 2003–2011
2 sentences

2011Specifically, it noted that obligation included the duty to properly address the forms and that a violation of the requirements of the statute is not "a mere technical error.” Id. (internal quotation marks omitted).

2008See Rivera v. State, 106 S.W.3d 635, 639 (Mo.App.2003); Yagovane, 923 S.W.2d at 523 .

13
Rivera v. Stategreen
moctapp · 2003 · cited in 2 Missouri opinions naming this issue, 2008–2011
2 sentences

2011Importantly, “[n]otice to both the prosecutor and the appropriate court is considered an essential element; therefore, lack of notice to one is not a mere technical error.” Id.

2008See Rivera v. State, 106 S.W.3d 635, 639 (Mo.App.2003); Yagovane, 923 S.W.2d at 523 .

12
State v. Smithgreen
moctapp · 1985 · cited in 2 Missouri opinions naming this issue, 1996–1996
2 sentences

1996A violation of the requirements of the statute is not “a mere technical error.” Smith, 686 S.W.2d at 547 .

1996A violation of the requirements of the statute is not ‘a mere technical error.’ ” Jamison v. State, 918 S.W.2d 889, 892 (Mo.App.1996)(quoting State v. Jenkins, 778 S.W.2d 815, 817 (Mo.App.1989) and State v. Smith, 686 S.W.2d 543, 547 (Mo.App.1985)).

12
Wanda Mayes v. Saint Luke's Hospital of Kansas City, (Consolidated with)Wanda Mayes v. Saint Luke's Hospital of Kansas Citygreen
mo · 2014 · cited in 1 Missouri opinions naming this issue, 2022–2022
1 sentence

2022As recognized in Mayes v. Saint Luke’s Hospital of Kansas City, 430 S.W.3d 260, 271 (Mo. banc 2014), caselaw suggests substantial compliance cannot satisfy section 538.225.

11
Lechner v. Whitesell Ex Rel. Whitesellgreen
moctapp · 1991 · cited in 1 Missouri opinions naming this issue, 2009–2009
1 sentence

2009Cf. Lechner, 811 S.W.2d at 861 (stating that the appointment of a GAL for a minor child is more than a mere technical defense, but is mandatory and a suit shall not be prosecuted further until such a guardian is appointed).

11
State v. Lassengreen
moctapp · 1984 · cited in 1 Missouri opinions naming this issue, 2000–2000
2 sentences

2000State v. Lassen, 679 S.W.2d 363, 368 (Mo.App.1984).

2000State v. Lassen, 679 S.W.2d 363, 368 (Mo.App.1984).

11
State v. Jenkinsgreen
moctapp · 1989 · cited in 1 Missouri opinions naming this issue, 1996–1996
1 sentence

1996A violation of the requirements of the statute is not ‘a mere technical error.’ ” Jamison v. State, 918 S.W.2d 889, 892 (Mo.App.1996)(quoting State v. Jenkins, 778 S.W.2d 815, 817 (Mo.App.1989) and State v. Smith, 686 S.W.2d 543, 547 (Mo.App.1985)).

11
Jamison v. Stategreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 1996–1996
1 sentence

1996A violation of the requirements of the statute is not ‘a mere technical error.’ ” Jamison v. State, 918 S.W.2d 889, 892 (Mo.App.1996)(quoting State v. Jenkins, 778 S.W.2d 815, 817 (Mo.App.1989) and State v. Smith, 686 S.W.2d 543, 547 (Mo.App.1985)).

11
State v. Howardgreen
mo · 1893 · cited in 1 Missouri opinions naming this issue, 1992–1992
2 sentences

1992For an example of a case involving a mere technical violation, see State v. Howard, 118 Mo. 127 , 24 S.W. 41, 43 (1893), where this Court found no grounds for reversal where an attorney was nominally appointed to defend a client, obtained no confidential information, and later assisted in prosecution.

1992For an example of a case involving a mere technical violation, see State v. Howard, 118 Mo. 127 , 24 S.W. 41, 43 (1893), where this Court found no grounds for reversal where an attorney was nominally appointed to defend a client, obtained no confidential information, and later assisted in prosecution.

11
Tracy v. Martin Ex Rel. Gunngreen
mo · 1952 · cited in 1 Missouri opinions naming this issue, 1976–1976
2 sentences

1976Nor is the appointment a bare technicality, and it is something more than a mere technical defense that is required of the guardian.” Tracy v. Martin, 363 Mo. 108 , 249 S.W.2d 321, 323 (banc 1952).

1976Nor is the appointment a bare technicality, and it is something more than a mere technical defense that is required of the guardian.” Tracy v. Martin, 363 Mo. 108 , 249 S.W.2d 321, 323 (banc 1952).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Spotts v. Spotts green
· 1932
2 sentences

1971Nor is the appointment a bare technicality, and it is something more than a mere technical defense that is required of the guardian.” In Spotts v. Spotts, 331 Mo. 917, 931 , 55 S.W.2d 977, 983 , the Supreme Court said: “This court has clearly stated that the appointment of a guardian ad litem for an infant defendant is not a bare technicality and that the office does not involve only perfunctory or shadowy duties, saying : ‘This guardian is to do for him what with riper judgment he would do for himself.

1971Nor is the appointment a bare technicality, and it is something more than a mere technical defense that is required of the guardian.” In Spotts v. Spotts, 331 Mo. 917, 931 , 55 S.W.2d 977, 983 , the Supreme Court said: “This court has clearly stated that the appointment of a guardian ad litem for an infant defendant is not a bare technicality and that the office does not involve only perfunctory or shadowy duties, saying : ‘This guardian is to do for him what with riper judgment he would do for himself.

21952–1971
State of Missouri v. Tawanda Kunonga green
moctapp · 2016
1 sentence

2024A second exception is when the State "effectively demonstrates that an unpreserved violation of section 600.051 is a mere technical violation having no impact on the knowing, voluntary, and intelligent waiver of counsel because the 5 While not an "exception[,]" our Supreme Court "has clarified that section 600.051 is not implicated when a defendant is provided 'standby' or 'hybrid' counsel because the defendant 'has not actually waived counsel.'" Kunonga, 490 S.W.3d at 766 (quoting Hunter, 840 S.W.2d at 860 )).

12024–2024
State v. Hunter green
mo · 1992
1 sentence

2024A second exception is when the State "effectively demonstrates that an unpreserved violation of section 600.051 is a mere technical violation having no impact on the knowing, voluntary, and intelligent waiver of counsel because the 5 While not an "exception[,]" our Supreme Court "has clarified that section 600.051 is not implicated when a defendant is provided 'standby' or 'hybrid' counsel because the defendant 'has not actually waived counsel.'" Kunonga, 490 S.W.3d at 766 (quoting Hunter, 840 S.W.2d at 860 )).

12024–2024
Fex v. Michigan green
scotus · 1993
2 sentences

2011In Fex v. Michigan, 507 U.S. 43, 52 , 113 S.Ct. 1085, 1091 , 122 L.Ed.2d 406 (1993), the United States Supreme Court held that “the 180-day time period in Article 111(a) of the IAD does not commence until the prisoner’s request for final disposition of the charges against him has actually been delivered to the court and the prosecuting officer of the jurisdiction that lodged the detainer against him.” Thus, Carbaugh did not trigger the 180-day limitation period because he did not show that he requested final disposition from the Circuit Court of Maries County, where the detainers were issued.

2011In Fex v. Michigan, 507 U.S. 43, 52 , 113 S.Ct. 1085, 1091 , 122 L.Ed.2d 406 (1993), the United States Supreme Court held that “the 180-day time period in Article 111(a) of the IAD does not commence until the prisoner’s request for final disposition of the charges against him has actually been delivered to the court and the prosecuting officer of the jurisdiction that lodged the detainer against him.” Thus, Carbaugh did not trigger the 180-day limitation period because he did not show that he requested final disposition from the Circuit Court of Maries County, where the detainers were issued.

12011–2011
Dennis Allen Brown v. Charles L. Wolff, and Richard H. Bryan, Attorney-General of the State of Nevada green
ca9 · 1983
1 sentence

1985Brown v. Wolff, supra. The agreement is to be construed in favor of the prisoner.

11985–1985

Where else courts name it

CA 53 (1892–2026) IL 45 (1914–2026) NY 27 (1878–2023) PA 22 (1914–2023) MO 14 (1952–2024) IA 10 (1885–2021) NC 8 (1974–2009) OH 7 (1983–2025) LA 7 (1962–2026) FL 7 (1960–2001) VT 6 (1984–2017) SC 6 (1940–1998) UT 5 (1978–2026) TX 5 (1952–2013) KS 4 (1897–2016) MS 4 (1990–2024) MN 4 (1991–1997) WV 4 (1900–2008) OR 4 (1978–1995) WA 3 (2001–2023) VA 3 (1987–2022) MT 3 (1922–1977) GA 3 (1918–1985) MI 3 (1991–2024) OK 3 (1929–1997) WI 3 (2002–2011) NJ 3 (1978–2009) AZ 2 (1927–1969) ID 2 (1992–2011) RI 2 (1959–2004) AL 2 (1930–1981) CO 2 (1971–1980) NM 2 (2012–2018) HI 2 (2013–2017) DC 2 (1943–1988)

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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