general preservation requirement (Alabama) · Go Syfert
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general preservation requirement in Alabama

13 Alabama opinions name it 2 courts 1986–2024 1 in the last five years

The cases below were cited by Alabama 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 (3)

CaseFollowedCited
Banks v. Stategreen
alacrimapp · 2010 · cited in 5 Alabama opinions naming this issue, 2015–2024
2 sentences

2018App. 2015), we noted: "This Court has previously held, however, that 'the requirement that the defendant be afforded the opportunity to speak on his or her behalf at the sentencing hearing [is an] exception[ ] to the general preservation rule and [is] required to afford a defendant the minimal due process.' Banks v. State , 51 So.3d 386 , 392 (Ala. Crim.

2018App. 2015), we noted: "This Court has previously held, however, that 'the requirement that the defendant be afforded the opportunity to speak on his or her behalf at the sentencing hearing [is an] exception[ ] to the general preservation rule and [is] required to afford a defendant the minimal due process.' Banks v. State , 51 So.3d 386 , 392 (Ala. Crim.

25
Green v. Stategreen
alacrimapp · 2015 · cited in 1 Alabama opinions naming this issue, 2024–2024
1 sentence

2024P. Although C.C. did not raise this claim below, this Court has held that " 'the requirement that the defendant be afforded the opportunity to speak on his or her behalf at the sentencing hearing [is an] exception[ ] to the general preservation rule and [is] required to afford a defendant the minimal due process.' " Green v. State, 200 So. 3d 677, 678 (Ala. Crim.

11
Shaw v. Stategreen
alacrimapp · 2006 · cited in 1 Alabama opinions naming this issue, 2015–2015
1 sentence

2015See Shaw v. State, 949 So.2d 184 (Ala.Crim.App.2006) (“A claim that a defendant was not afforded the opportunity to address the court before the sentence is imposed is not a jurisdictional claim.”).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Gagnon v. Scarpelli red
scotus · 1973
2 sentences

2004Before the circuit court can revoke probation, the court must provide a written order stating the evidence and the reasons it relied upon to revoke probation in order to comply with the due-process requirements of Gagnon v. Scarpelli , 411 U.S. 778 , 93 S.Ct. 1756 , 36 L.Ed.2d 656 (1973).

2004Before the circuit court can revoke probation, the court must provide a written order stating the evidence and the reasons it relied upon to revoke probation in order to comply with the due-process requirements of Gagnon v. Scarpelli , 411 U.S. 778 , 93 S.Ct. 1756 , 36 L.Ed.2d 656 (1973).

72001–2004
Ex Parte State green
ala · 1992
1 sentence

2003Before probation can be revoked, the circuit court must provide a written order stating the evidence and the reasons relied upon to revoke probation in order to comply with the due-process requirements of Gagnon v. Scarpelli , supra. Wyatt v. State , 608 So.2d 762 (Ala. 1992); Armstrong v. State , supra. While the circuit court's order on revocation adequately states the reasons for revoking Beckham's probation, the order fails to adequately specify the evidence it relied upon.

12003–2003
United States v. Donald G. Richardson and Robert H. Wilson green
ca7 · 1977
1 sentence

1986Then, relying on United States v. Richardson , 562 F.2d 476 (7th Cir. 1977), cert. denied 434 U.S. 1072 , 98 S.Ct. 1257 , 55 L.Ed.2d 776 (1978), the court summarily declared: "We likewise do not believe that this is plain error, and furthermore, we find that the appellant's action, or inaction, constituted a waiver.

11986–1986
Preston v. Georgia green
scotus · 1978
1 sentence

1986Then, relying on United States v. Richardson , 562 F.2d 476 (7th Cir. 1977), cert. denied 434 U.S. 1072 , 98 S.Ct. 1257 , 55 L.Ed.2d 776 (1978), the court summarily declared: "We likewise do not believe that this is plain error, and furthermore, we find that the appellant's action, or inaction, constituted a waiver.

11986–1986
Brown v. Blankenship green
scotus · 1978
1 sentence

1986Then, relying on United States v. Richardson , 562 F.2d 476 (7th Cir. 1977), cert. denied 434 U.S. 1072 , 98 S.Ct. 1257 , 55 L.Ed.2d 776 (1978), the court summarily declared: "We likewise do not believe that this is plain error, and furthermore, we find that the appellant's action, or inaction, constituted a waiver.

11986–1986

Statutes the citing opinions construe

AL § Ala. Code § 13A-6-61 (3) AL § Ala. Code § 13A-6-63 (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 22 (2009–2026) AL 13 (1986–2024) KS 11 (2012–2026) UT 10 (2012–2024) NM 3 (2002–2025) FL 2 (2005–2005) AK 2 (2014–2015) NY 2 (2002–2023)

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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