sound framework (Utah) · Go Syfert
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sound framework in Utah

14 Utah opinions name it 2 courts 1943–2025 6 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 (9)

CaseFollowedCited
State v. Pedockiegreen
utah · 2006 · cited in 6 Utah opinions naming this issue, 2023–2025
2 sentences

2025And our supreme court has noted that “the sixteen-point colloquy found in State v. Frampton establishes a sound framework for efficient and complete questioning” while also providing “the reviewing court with an objective basis for review upon the almost inevitable challenge to the waiver by the defendant who proceeds pro se and is subsequently convicted.” Pedockie, 2006 UT 28, ¶ 42 (cleaned up).

2025Our supreme court has indicated that “[t]he sixteen-point colloquy found in State v. Frampton establishes a sound framework for efficient and complete questioning.” Pedockie, 2006 UT 28, ¶ 42 (footnote omitted).

56
State v. Bozarthgreen
utahctapp · 2021 · cited in 1 Utah opinions naming this issue, 2025–2025
2 sentences

2025And the supreme court has since held that this colloquy “establishes a sound framework for efficient and complete questioning.” Pedockie, 2006 UT 28, ¶ 42 ; see also West, 2023 UT App 61, ¶ 31 (“Such questioning is the encouraged practice for courts, utilizing Frampton’s sixteen-point guide as a framework to ensure a defendant is making the decision to proceed pro se knowingly and intelligently.” (quotation simplified)). ¶25 We’ve stated that compliance with the Frampton colloquy is “not mandatory,” State v. Bozarth, 2021 UT App 117, ¶ 41 , 501 P.3d 116 , and that its questions are “not talism

2025And the supreme court has since held that this colloquy “establishes a sound framework for efficient and complete questioning.” Pedockie, 2006 UT 28, ¶ 42 ; see also West, 2023 UT App 61, ¶ 31 (“Such questioning is the encouraged practice for courts, utilizing Frampton’s sixteen-point guide as a framework to ensure a defendant is making the decision to proceed pro se knowingly and intelligently.” (quotation simplified)). ¶25 We’ve stated that compliance with the Frampton colloquy is “not mandatory,” State v. Bozarth, 2021 UT App 117, ¶ 41 , 501 P.3d 116 , and that its questions are “not talism

11
State v. Waterfieldgreen
utahctapp · 2014 · cited in 1 Utah opinions naming this issue, 2025–2025
2 sentences

2025And the supreme court has since held that this colloquy “establishes a sound framework for efficient and complete questioning.” Pedockie, 2006 UT 28, ¶ 42 ; see also West, 2023 UT App 61, ¶ 31 (“Such questioning is the encouraged practice for courts, utilizing Frampton’s sixteen-point guide as a framework to ensure a defendant is making the decision to proceed pro se knowingly and intelligently.” (quotation simplified)). ¶25 We’ve stated that compliance with the Frampton colloquy is “not mandatory,” State v. Bozarth, 2021 UT App 117, ¶ 41 , 501 P.3d 116 , and that its questions are “not talism

2025And the supreme court has since held that this colloquy “establishes a sound framework for efficient and complete questioning.” Pedockie, 2006 UT 28, ¶ 42 ; see also West, 2023 UT App 61, ¶ 31 (“Such questioning is the encouraged practice for courts, utilizing Frampton’s sixteen-point guide as a framework to ensure a defendant is making the decision to proceed pro se knowingly and intelligently.” (quotation simplified)). ¶25 We’ve stated that compliance with the Frampton colloquy is “not mandatory,” State v. Bozarth, 2021 UT App 117, ¶ 41 , 501 P.3d 116 , and that its questions are “not talism

11
State v. Westgreen
utahctapp · 2023 · cited in 1 Utah opinions naming this issue, 2025–2025
2 sentences

2025And the supreme court has since held that this colloquy “establishes a sound framework for efficient and complete questioning.” Pedockie, 2006 UT 28, ¶ 42 ; see also West, 2023 UT App 61, ¶ 31 (“Such questioning is the encouraged practice for courts, utilizing Frampton’s sixteen-point guide as a framework to ensure a defendant is making the decision to proceed pro se knowingly and intelligently.” (quotation simplified)). ¶25 We’ve stated that compliance with the Frampton colloquy is “not mandatory,” State v. Bozarth, 2021 UT App 117, ¶ 41 , 501 P.3d 116 , and that its questions are “not talism

2025But even so, our supreme court has explained that this colloquy is the “preferred method” of ascertaining whether the defendant is “aware of the dangers and disadvantages of self-representation.” Pedockie, 2006 UT 28, ¶ 42 (quotation simplified); accord West, 2023 UT App 61 , ¶ 32 n.6.

11
State v. Dixongreen
utah · 1977 · cited in 1 Utah opinions naming this issue, 2001–2001
1 sentence

2001See Jenkins v. Parrish, 627 P.2d 533, 536 (Utah 1981); State v. Dixon, 560 P.2d 318, 319 (Utah 1977).

11
Jenkins v. Parrishgreen
utah · 1981 · cited in 1 Utah opinions naming this issue, 2001–2001
1 sentence

2001See Jenkins v. Parrish, 627 P.2d 533, 536 (Utah 1981); State v. Dixon, 560 P.2d 318, 319 (Utah 1977).

11
Wetzel v. Wetzelgreen
wis · 1967 · cited in 1 Utah opinions naming this issue, 1983–1983
2 sentences

1983Wetzel v. Wetzel, 35 Wis.2d 103 , 150 N.W.2d 482, 485 (1967), stated the sound principle that such friction ought to be avoided: The elimination of the source of strife and friction is to be sought and the financial affairs of the divorced parties separated as far as possible.

1983Wetzel v. Wetzel, 35 Wis.2d 103 , 150 N.W.2d 482, 485 (1967), stated the sound principle that such friction ought to be avoided: The elimination of the source of strife and friction is to be sought and the financial affairs of the divorced parties separated as far as possible.

11
Sterling Press v. Pettitgreen
utah · 1978 · cited in 1 Utah opinions naming this issue, 1982–1982
1 sentence

1982Under that section an “authorized representative” who signs his name to an “instrument” is nevertheless personally obligated “if the instrument neither names the person represented nor shows that the representative signed in a representative capacity . ... ” We believe that this rule, which was applied in Sterling Press v. Pettit, Utah, 580 P.2d 599, 600 (1978), is a sound rule for contracts as well as for commercial paper, and an appropriate elaboration on our decision in Mortgage Investment Co. v. Toone, supra. The rule dictates that the judgment against the defendant in this case be affirme

11
Scott v. Waltongreen
or · 1898 · cited in 1 Utah opinions naming this issue, 1976–1976
2 sentences

1976See Scott v. Walton, 32 Or. 460 , 52 P. 180 (1898) where it is stated that a party “cannot retain the fruits of the contract awaiting future development to determine whether it will be more profitable for him to affirm or disaffirm it.” And see statement in Farrington v. Granite State Fire Ins.

1976See Scott v. Walton, 32 Or. 460 , 52 P. 180 (1898) where it is stated that a party “cannot retain the fruits of the contract awaiting future development to determine whether it will be more profitable for him to affirm or disaffirm it.” And see statement in Farrington v. Granite State Fire Ins.

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 (8)

CaseCitedYears
State v. Patton green
utahctapp · 2023
2 sentences

2025And “[w]hile a waiver colloquy need not follow this precise script,” State v. Patton, 2023 UT App 33, ¶ 14 , 528 P.3d 1249 , “our supreme court has urged and strongly recommended trial courts to employ the full Frampton colloquy,” id. ¶ 14 n.5 (cleaned up). ¶26 Here, after Bridgewaters made his unequivocal request, the trial court was obligated to determine whether he was knowingly and intelligently waiving his right to counsel, preferably by conducting a full Frampton colloquy.

2023See id.; see also Pedockie, 2006 UT 28, ¶ 42 (“The sixteen-point colloquy found in State v. Frampton establishes a sound framework for efficient and complete questioning.”); cf. State v. Patton, 2023 UT App 33 , ¶ 14 n.5 (“We encourage trial courts to keep a prepared Frampton waiver-of-counsel colloquy script at the ready on the bench, for use when the occasion arises.”). ¶32 Absent a colloquy, it is still possible for a reviewing court to find that a defendant’s waiver was validly made after examining “any evidence in the record which shows a defendant’s actual awareness of the risks of proce

32023–2025
State v. Frampton green
utah · 1987
2 sentences

2023Frampton, 737 P.2d at 187 n.12 (quoting Bench Book for U.S. District Court Judges, vol. 1 §§ 1.02-2 to -5 (Federal Judicial Center, 3d ed. 1986)).4 While a waiver colloquy need not follow this precise script, “the sixteen-point colloquy found in State v. Frampton establishes a sound framework for efficient and complete questioning.

2023Frampton, 737 P.2d at 188 .

22023–2023
State v. Bridgewaters green
utahctapp · 2025
1 sentence

2025Our supreme court has indicated that “[t]he sixteen-point colloquy found in 20221065-CA 14 2025 UT App 184 State v. Bridgewaters State v. Frampton establishes a sound framework for efficient and complete questioning.” Pedockie, 2006 UT 28, ¶ 42 (footnote omitted).

12025–2025
Clark v. Detroit & Mackinac Railway Co. green
mich · 1917
2 sentences

1990For example, in Clark v. Detroit & Mackinac Ry., 197 Mich. 489 , 163 N.W. 964 (1917), a rowboat rented from the defendant capsized, causing four minors to drown.

1990For example, in Clark v. Detroit & Mackinac Ry., 197 Mich. 489 , 163 N.W. 964 (1917), a rowboat rented from the defendant capsized, causing four minors to drown.

11990–1990
State v. Baker green
utah · 1983
2 sentences

1983The problem that this Court has wrestled with must have also been encountered in a magnified form in the trial courts. *535 State v. Baker, supra , provides a sound analysis of the differing rules which govern the doctrine of lesser included offenses and the closely related doctrine that governs when a defendant is entitled to an instruction on his theory of the case.

1983State v. Baker, supra, provides a sound analysis of the differing rules which govern the doctrine of lesser included offenses and the closely related doctrine that governs when a defendant is entitled to an instruction on his theory of the case.

11983–1983
Brough v. Utah Stampede Ass'n, Inc. green
utah · 1943
2 sentences

1945Brough v. Ute Stampede Ass’n, 105 Utah 446 , 142 P. 2d 670 .

1945Brough v. Ute Stampede Ass’n, 105 Utah 446 , 142 P. 2d 670 .

11945–1945
Fleming v. Public Service Commission green
prsupreme · 1940
1 sentence

1943J., in Kimball v. Grantsville City et al., 19 Utah 368, 384 , 57 P. 1, 5 , 45 L.

11943–1943
Kimball v. Grantsville City green
utah · 1899
1 sentence

1943J., in Kimball v. Grantsville City et al., 19 Utah 368, 384 , 57 P. 1, 5 , 45 L.

11943–1943

Where else courts name it

GA 125 (1891–2025) NY 110 (1826–2023) TX 106 (1899–2026) PA 87 (1834–2026) CA 86 (1886–2023) TN 70 (1874–2021) AL 68 (1857–2014) IL 57 (1870–2025) NJ 53 (1828–2026) SC 44 (1942–2026) MA 42 (1892–2026) LA 42 (1882–2024) MI 41 (1884–2026) FL 37 (1881–2013) KY 35 (1865–2023) MO 32 (1870–1994) NC 29 (1896–2018) OH 28 (1849–2026) OK 28 (1898–2016) WA 25 (1914–2018) IA 24 (1887–2023) NE 24 (1890–2023) MD 22 (1853–2024) IN 22 (1859–2015) HI 21 (1889–2025) AR 21 (1872–1990) AZ 19 (1931–1999) MS 18 (1855–2019) KS 16 (1911–2022) DC 14 (1894–2016) UT 14 (1943–2025) WI 14 (1867–2016) CT 13 (1839–1994) CO 13 (1875–2002) WV 13 (1925–1995) WY 11 (1933–2003) DE 11 (1913–2022) ME 10 (1830–1987) MT 10 (1912–2023) SD 10 (1907–1968) ID 10 (1914–2014) MN 10 (1901–2026) VA 9 (1878–1994) NM 9 (1881–1994) ND 8 (1908–1967) RI 8 (1868–1972) VT 7 (1849–2015) PR 7 (1904–1970) NV 6 (1925–1994) OR 5 (1945–1983) NH 3 (1836–1978)

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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