issue as plain error (Missouri) · Go Syfert
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issue as plain error in Missouri

13 Missouri opinions name it 1 courts 1978–2021 1 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
Charles K. Moore v. State of Missourigreen
mo · 2015 · cited in 1 Missouri opinions naming this issue, 2021–2021
1 sentence

2021See Moore v. State, 458 S.W.3d 822 (Mo. banc 2015). 2 The motion court rejected these claims after a hearing and denied relief.

11
Collins v. Hertensteingreen
moctapp · 2002 · cited in 1 Missouri opinions naming this issue, 2006–2006
1 sentence

2006Appellants admit that by not objecting they failed to preserve the issue for review and ask this Court to review the issue as plain error under Rule 84.13(c). 3 An appellate court may review an issue using plain error if it determines that a “manifest injustice” or “miscarriage of justice has resulted from plain error.” Collins v. Hertenstein, 90 S.W.3d 87, 98 (Mo.App.2002).

11
State v. Kindergreen
mo · 1996 · cited in 1 Missouri opinions naming this issue, 2002–2002
1 sentence

2002See State v. Kinder, 942 S.W.2d 313, 323 (Mo. banc 1996); see also Rule 30.20.

11
Coats v. Hickmangreen
moctapp · 1999 · cited in 1 Missouri opinions naming this issue, 2000–2000
1 sentence

2000Coats v. Hickman, 11 S.W.3d 798, 805-06 (Mo.App.W.D. 1999).

11
State v. Browngreen
mo · 1995 · cited in 1 Missouri opinions naming this issue, 1998–1998
1 sentence

1998State v. Brown, 902 S.W.2d 278, 284 (Mo. banc), cert. denied, 516 U.S. 1031 , 116 S.Ct. 679 , 133 L.Ed.2d 527 (1995).

11
State v. Clemmonsgreen
mo · 1988 · cited in 1 Missouri opinions naming this issue, 1996–1996
1 sentence

1996The Supreme Court has instructed that “courtfe] should rarely grant relief on assertions of plain error as to closing argument[.] This is because, in the absence of objection and request for relief, the trial court’s options are narrowed to uninvited interference with summation and a corresponding increase of error by such intervention.” State v. Clemmons, 753 S.W.2d 901, 907-08 (Mo. banc), cert. denied, 488 U.S. 948 , 109 S.Ct. 380 , 102 L.Ed.2d 369 (1988).

11
State v. Gillespiegreen
moctapp · 1990 · cited in 1 Missouri opinions naming this issue, 1992–1992
1 sentence

1992State v. Gillespie, 792 S.W.2d 35, 36 (Mo.App.1990).

11
Disbrow v. Boehmergreen
moctapp · 1986 · cited in 1 Missouri opinions naming this issue, 1988–1988
1 sentence

1988See Disbrow v. Boehmer, 711 S.W.2d 917, 927 (Mo.App.1986); Arkansas-Missouri Power Company v. Haines, 592 S.W.2d 883, 885 (Mo.App.1980). [6] Before us plaintiff has not requested that we review this issue as plain error and, because we do not believe the error materially affected the merits of the action, Rule 84.13(b) nor that it resulted in manifest injustice or a miscarriage of justice, Rule 84.13(c), we decline to do so sua sponte.

11
Arkansas-Missouri Power Co. v. Hainesgreen
moctapp · 1980 · cited in 1 Missouri opinions naming this issue, 1988–1988
1 sentence

1988See Disbrow v. Boehmer, 711 S.W.2d 917, 927 (Mo.App.1986); Arkansas-Missouri Power Company v. Haines, 592 S.W.2d 883, 885 (Mo.App.1980). [6] Before us plaintiff has not requested that we review this issue as plain error and, because we do not believe the error materially affected the merits of the action, Rule 84.13(b) nor that it resulted in manifest injustice or a miscarriage of justice, Rule 84.13(c), we decline to do so sua sponte.

11
Wilborn v. Williamsgreen
moctapp · 1977 · cited in 1 Missouri opinions naming this issue, 1980–1980
1 sentence

1980However, generally, failure to object to an argument at the time counsel is addressing the jury results in a waiver of any rights to complain about the argument on appeal, Wilborn v. Williams, 555 S.W.2d 44, 46 (Mo.App.1977), because the trial court must be given an opportunity to take corrective action to cure any prejudicial effect of an erroneous argument.

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 (8)

CaseCitedYears
Wilkerson v. Mosley green
scotus · 1995
1 sentence

1998State v. Brown, 902 S.W.2d 278, 284 (Mo. banc), cert. denied, 516 U.S. 1031 , 116 S.Ct. 679 , 133 L.Ed.2d 527 (1995).

11998–1998
Mayes v. Newberry green
scotus · 1995
1 sentence

1998State v. Brown, 902 S.W.2d 278, 284 (Mo. banc), cert. denied, 516 U.S. 1031 , 116 S.Ct. 679 , 133 L.Ed.2d 527 (1995).

11998–1998
Clemmons v. Missouri green
scotus · 1988
1 sentence

1996The Supreme Court has instructed that “courtfe] should rarely grant relief on assertions of plain error as to closing argument[.] This is because, in the absence of objection and request for relief, the trial court’s options are narrowed to uninvited interference with summation and a corresponding increase of error by such intervention.” State v. Clemmons, 753 S.W.2d 901, 907-08 (Mo. banc), cert. denied, 488 U.S. 948 , 109 S.Ct. 380 , 102 L.Ed.2d 369 (1988).

11996–1996
Clemmons v. Missouri green
scotus · 1988
1 sentence

1996The Supreme Court has instructed that “courtfe] should rarely grant relief on assertions of plain error as to closing argument[.] This is because, in the absence of objection and request for relief, the trial court’s options are narrowed to uninvited interference with summation and a corresponding increase of error by such intervention.” State v. Clemmons, 753 S.W.2d 901, 907-08 (Mo. banc), cert. denied, 488 U.S. 948 , 109 S.Ct. 380 , 102 L.Ed.2d 369 (1988).

11996–1996
Sherpy v. Bilyeu green
moctapp · 1980
2 sentences

1995This court held the plaintiff waived the objection and in declining to review the issue as plain error stated, “Plain error is not a doctrine available to revive issues already abandoned by selection of trial strategy or by oversight.” 608 S.W.2d at 523 .

1995This court held the plaintiff waived the objection and in declining to review the issue as plain error stated, "Plain error is not a doctrine available to revive issues already abandoned by selection of trial strategy or by oversight." 608 S.W.2d at 523 .

11995–1995
Robbins v. Brown-Strauss Corp. green
mo · 1953
2 sentences

1980Manifest injustice not appearing, we decline to address the issue as plain error. *524 In her reply brief, plaintiff cites Robbins v. Brown-Strauss Corp., 363 Mo. 1157 , 257 S.W.2d 643 (1953), as authority for the proposition that a complaining party does not lose a right to relief by failing to object to closing argument.

1980Manifest injustice not appearing, we decline to address the issue as plain error. *524 In her reply brief, plaintiff cites Robbins v. Brown-Strauss Corp., 363 Mo. 1157 , 257 S.W.2d 643 (1953), as authority for the proposition that a complaining party does not lose a right to relief by failing to object to closing argument.

11980–1980
State v. Rothaus green
mo · 1975
1 sentence

1979I believe this case to be controlled by State v. Rothaus, 530 S.W.2d 235 (Mo. 1975). *536 I am more disturbed by the fact that we are asked to rule the issue as plain error under the circumstances of this case.

11979–1979
State v. Brown green
moctapp · 1975
1 sentence

1978State v. Brown, supra, 525 S.W.2d l.c. 567[3].

11978–1978

Where else courts name it

IL 114 (1975–2026) TN 64 (2003–2026) MS 15 (1998–2016) MO 13 (1978–2021) OR 6 (2014–2026) HI 3 (1998–2007) NH 2 (2009–2022)

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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