defendant did not preserve error (Texas) · Go Syfert
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defendant did not preserve error in Texas

14 Texas opinions name it 2 courts 1985–2023 1 in the last five years

The cases below were cited by Texas 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 (9)

CaseFollowedCited
Smith, William A/K/A Bill Smithgreen
texcrimapp · 2016 · cited in 3 Texas opinions naming this issue, 2018–2018
2 sentences

2018For example, in Smith v. State, a bench-trial case, the Court of Criminal Appeals concluded that, although a defendant had objected to the admission of evidence and the trial court had carried the objection with the case, the defendant did not preserve error when the trial judge admitted the evidence unaccompanied by a ruling on the complaint. 499 S.W.3d 1, 5 (Tex. Crim.

2018For example, in Smith v. State, a bench-trial case, the Court of Criminal Appeals concluded that, although a defendant had objected to the admission of evidence and the trial court had carried the objection with the case, the defendant did not preserve error when the trial judge admitted the evidence unaccompanied by a ruling on the complaint. 499 S.W.3d 1, 5 (Tex. Crim.

33
Almanza v. Stategreen
texcrimapp · 1985 · cited in 2 Texas opinions naming this issue, 2009–2016
2 sentences

2016To determine “some harm,” the appellate court evaluates “(1) the jury charge as a whole, (2) the arguments of counsel, (3) the entirety of the evidence, and (4) other relevant factors present in the record.” Id. (citing Wooten v. State, 400 S.W.3d 601, 606 (Tex.Crim.App.2013)); see also Segovia v. State, 467 S.W.3d 545, 556 (Tex.App.-San Antonio 2015, pet. ref'd). ■ By contrast, if the defendant did not preserve error, the defendant must “show .that the error was ‘fundamental’ and that.he suffered ‘egregious harm.’” Reeves, 420 S.W.3d at 816 (quoting Alman-za, 686 S.W.2d at 171 ). “‘This is a

2016To determine “some harm,” the appellate court evaluates “(1) the jury charge as a whole, (2) the arguments of counsel, (3) the entirety of the evidence, and (4) other relevant factors present in the record.” Id. (citing Wooten v. State, 400 S.W.3d 601, 606 (Tex.Crim.App.2013)); see also Segovia v. State, 467 S.W.3d 545, 556 (Tex.App.-San Antonio 2015, pet. ref'd). ■ By contrast, if the defendant did not preserve error, the defendant must “show .that the error was ‘fundamental’ and that.he suffered ‘egregious harm.’” Reeves, 420 S.W.3d at 816 (quoting Alman-za, 686 S.W.2d at 171 ). “‘This is a

22
Young v. Stategreen
texcrimapp · 2009 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016To determine “some harm,” the appellate court evaluates “(1) the jury charge as a whole, (2) the arguments of counsel, (3) the entirety of the evidence, and (4) other relevant factors present in the record.” Id. (citing Wooten v. State, 400 S.W.3d 601, 606 (Tex.Crim.App.2013)); see also Segovia v. State, 467 S.W.3d 545, 556 (Tex.App.-San Antonio 2015, pet. ref'd). ■ By contrast, if the defendant did not preserve error, the defendant must “show .that the error was ‘fundamental’ and that.he suffered ‘egregious harm.’” Reeves, 420 S.W.3d at 816 (quoting Alman-za, 686 S.W.2d at 171 ). “‘This is a

11
Gearhart v. Stategreen
texapp · 2003 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016App. 2010), cert. denied, 562 U.S. 1142 (2011); Thierry v. State, 288 S.W.3d 80 , 84–85 (Tex. App.—Houston [1st Dist.] 2009, pet. ref’d); Gearhart v. State, 122 S.W.3d 459, 465 (Tex. App.—Corpus Christi 2003, pet. ref’d); see also Brown v. 3 State, No. 02-04-00405-CR, 2006 WL 413448 , at *3 (Tex. App.—Fort Worth Feb. 23, 2006, no pet.) (mem. op., not designated for publication) (holding that a defendant did not preserve error concerning the State’s opening statement because he did not obtain an adverse ruling on objections to the statement); Ogaz v. State, No. 02-03-00419-CR, 2005 WL 2898139 ,

11
Andres Alfredo Segovia v. Stategreen
texapp · 2015 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016To determine “some harm,” the appellate court evaluates “(1) the jury charge as a whole, (2) the arguments of counsel, (3) the entirety of the evidence, and (4) other relevant factors present in the record.” Id. (citing Wooten v. State, 400 S.W.3d 601, 606 (Tex.Crim.App.2013)); see also Segovia v. State, 467 S.W.3d 545, 556 (Tex.App.-San Antonio 2015, pet. ref'd). ■ By contrast, if the defendant did not preserve error, the defendant must “show .that the error was ‘fundamental’ and that.he suffered ‘egregious harm.’” Reeves, 420 S.W.3d at 816 (quoting Alman-za, 686 S.W.2d at 171 ). “‘This is a

11
Reeves, Gary Patrickgreen
texcrimapp · 2013 · cited in 1 Texas opinions naming this issue, 2016–2016
2 sentences

2016To determine “some harm,” the appellate court evaluates “(1) the jury charge as a whole, (2) the arguments of counsel, (3) the entirety of the evidence, and (4) other relevant factors present in the record.” Id. (citing Wooten v. State, 400 S.W.3d 601, 606 (Tex.Crim.App.2013)); see also Segovia v. State, 467 S.W.3d 545, 556 (Tex.App.-San Antonio 2015, pet. ref'd). ■ By contrast, if the defendant did not preserve error, the defendant must “show .that the error was ‘fundamental’ and that.he suffered ‘egregious harm.’” Reeves, 420 S.W.3d at 816 (quoting Alman-za, 686 S.W.2d at 171 ). “‘This is a

2016To determine “some harm,” the appellate court evaluates “(1) the jury charge as a whole, (2) the arguments of counsel, (3) the entirety of the evidence, and (4) other relevant factors present in the record.” Id. (citing Wooten v. State, 400 S.W.3d 601, 606 (Tex.Crim.App.2013)); see also Segovia v. State, 467 S.W.3d 545, 556 (Tex.App.-San Antonio 2015, pet. ref'd). ■ By contrast, if the defendant did not preserve error, the defendant must “show .that the error was ‘fundamental’ and that.he suffered ‘egregious harm.’” Reeves, 420 S.W.3d at 816 (quoting Alman-za, 686 S.W.2d at 171 ). “‘This is a

11
Wooten, Codiem Renoirgreen
texcrimapp · 2013 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016To determine “some harm,” the appellate court evaluates “(1) the jury charge as a whole, (2) the arguments of counsel, (3) the entirety of the evidence, and (4) other relevant factors present in the record.” Id. (citing Wooten v. State, 400 S.W.3d 601, 606 (Tex.Crim.App.2013)); see also Segovia v. State, 467 S.W.3d 545, 556 (Tex.App.-San Antonio 2015, pet. ref'd). ■ By contrast, if the defendant did not preserve error, the defendant must “show .that the error was ‘fundamental’ and that.he suffered ‘egregious harm.’” Reeves, 420 S.W.3d at 816 (quoting Alman-za, 686 S.W.2d at 171 ). “‘This is a

11
Hutch v. Stategreen
texcrimapp · 1996 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016An eiTor in the charge is egregious only if it “affect[s] ‘the very basis of the case,’ deprive[s] the defendant of a ‘valuable right,’ or ‘vitally affect[s] a defensive theory.’ ” Hutch v. State, 922 S.W.2d, 166, 170 (Tex.Crim.App.1996) (quoting Almanza, 686 S.W.2d at 172 ).

11
Nelson v. Stategreen
texcrimapp · 1983 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015Id. at 124−25 (Teague, J., concurring).

2015Id. at 124-25 (Teague, J., concurring).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
Ngo v. State green
texcrimapp · 2005
2 sentences

2015If the defendant did not preserve error, we will reverse only if the record shows “egregious harm.” Ngo, 175 S.W.3d at 743-44 ; Kuhn, 393 S.W.3d at 524 .

2015If the defendant did not preserve error, we will reverse only if the record shows “egregious harm.” Ngo, 175 S.W.3d at 743-44 ; Kuhn, 393 S.W.3d at 524 .

22015–2015
Bill Boyd Kuhn v. State green
texapp · 2013
2 sentences

2015If the defendant did not preserve error, we will reverse only if the record shows “egregious harm.” Ngo, 175 S.W.3d at 743-44 ; Kuhn, 393 S.W.3d at 524 .

2015If the defendant did not preserve error, we will reverse only if the record shows “egregious harm.” Ngo, 175 S.W.3d at 743-44 ; Kuhn, 393 S.W.3d at 524 .

22015–2015
Goforth v. Alvey green
tex · 1954
1 sentence

2023Id.

12023–2023
Miranda Renea Kelso v. State green
texapp · 2018
1 sentence

2019Id.

12019–2019
Irby v. Texas green
scotus · 2011
1 sentence

2016App. 2010), cert. denied, 562 U.S. 1142 (2011); Thierry v. State, 288 S.W.3d 80 , 84–85 (Tex. App.—Houston [1st Dist.] 2009, pet. ref’d); Gearhart v. State, 122 S.W.3d 459, 465 (Tex. App.—Corpus Christi 2003, pet. ref’d); see also Brown v. 3 State, No. 02-04-00405-CR, 2006 WL 413448 , at *3 (Tex. App.—Fort Worth Feb. 23, 2006, no pet.) (mem. op., not designated for publication) (holding that a defendant did not preserve error concerning the State’s opening statement because he did not obtain an adverse ruling on objections to the statement); Ogaz v. State, No. 02-03-00419-CR, 2005 WL 2898139 ,

12016–2016
Thierry v. State green
texapp · 2009
1 sentence

2016App. 2010), cert. denied, 562 U.S. 1142 (2011); Thierry v. State, 288 S.W.3d 80 , 84–85 (Tex. App.—Houston [1st Dist.] 2009, pet. ref’d); Gearhart v. State, 122 S.W.3d 459, 465 (Tex. App.—Corpus Christi 2003, pet. ref’d); see also Brown v. 3 State, No. 02-04-00405-CR, 2006 WL 413448 , at *3 (Tex. App.—Fort Worth Feb. 23, 2006, no pet.) (mem. op., not designated for publication) (holding that a defendant did not preserve error concerning the State’s opening statement because he did not obtain an adverse ruling on objections to the statement); Ogaz v. State, No. 02-03-00419-CR, 2005 WL 2898139 ,

12016–2016
Marini v. State green
texcrimapp · 1980
1 sentence

2005In Marini , the court held that the defendant did not preserve error because he failed to timely object to an officer’s testimony regarding narcotics, and, in a footnote, the court expressly stated that the defendant’s motion to suppress his oral confession did not embrace the admission of the evidence to which the defendant was objecting at trial. 593 S.W.2d at 714 .

12005–2005
Thomas v. State green
texapp · 1994
1 sentence

2005In Thomas , the defendant did not obtain a hearing or a ruling on his motion to suppress evidence, so the defendant was required to object to the evidence at the earliest opportunity to preserve error. 884 S.W.2d at 216-17 .

12005–2005
Turner v. State green
texapp · 1982
1 sentence

2005In Turner , the defendant did not preserve error because he had not filed a motion to suppress evidence and did not object until after the officer testified about the arrest and subsequent search. 642 S.W.2d at 217 .

12005–2005
Hefner v. State green
texapp · 1987
2 sentences

2000In Hefner , the court held the defendant did not preserve error because he requested only a general mistake *375 of fact instruction that completely failed to apply the defense to the facts of the case. 735 S.W.2d at 620 .

2000In Hefner , the court held the defendant did not preserve error because he requested only a general mistake *375 of fact instruction that completely failed to apply the defense to the facts of the case. 735 S.W.2d at 620 .

12000–2000
Williams v. State green
texapp · 1996
1 sentence

2000In Williams , this Court held the defendant did not preserve error because he did not specify how the mistake of fact defense applied to the facts of that case. 930 S.W.2d at 903 .

12000–2000
Frausto v. State green
texcrimapp · 1982
2 sentences

1985Finally, in Frausto v. State, 642 S.W.2d 506 (Tex.Crim.App.1982), the prosecutor read the enhancement clause to the veniremen during voir dire.

1985Finally, in Frausto v. State, 642 S.W.2d 506 (Tex.Crim.App.1982), the prosecutor read the enhancement clause to the veniremen during voir dire.

11985–1985

Statutes the citing opinions construe

TX § Tex. Penal Code § 22.02 (4) TX § Tex. Penal Code § 12.31 (3) TX § Tex. Penal Code § 12.32 (3) TX § Tex. Penal Code § 12.33 (3) TX § Tex. Penal Code § 15.01 (3) TX § Tex. Penal Code § 19.03 (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

TX 14 (1985–2023) IA 4 (1993–2015)

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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