influence error (Texas) · Go Syfert
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influence error in Texas

84 Texas opinions name it 2 courts 1927–2025 7 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 (13)

CaseFollowedCited
Burnett v. Stategreen
texcrimapp · 2002 · cited in 64 Texas opinions naming this issue, 2002–2025
2 sentences

2021Instead, “it is the reviewing court’s duty to assess harm after conducting a proper review of the record to determine the influence the error had in light of all the other evidence.” Id. (citing Kotteakos v. United States, 328 U.S. 750, 762 (1946)).

2015We cannot reverse a criminal conviction unless we have “‘a grave doubt’ that the result was free from the substantial influence of the error . . . . ‘Grave doubt’ means that ‘in the judge’s mind, the matter is so evenly balanced that he feels himself in virtual equipoise as to the harmlessness of the error.’” Burnett v. State, 88 S.W.3d 633 , 637–38 (Tex. Crim.

2664
United States v. Lanegreen
scotus · 1986 · cited in 3 Texas opinions naming this issue, 2006–2015
2 sentences

2015United States v. Lane, 474 U.S. 438, 449 (1986); Burnett v. State, 88 S.W.3d 633, 638 (Tex. Crim.

2006“Grave doubt” means that “in the judge’s mind, the matter is so evenly balanced that he feels himself in virtual equipoise as to the harmlessness of the error.” Thus, “in cases of grave doubt as to harmlessness the petitioner must win.” Id . at 637-38 (quoting United States v. Lane , 474 U.S. 438, 449 (1986) and O’Neal v. McAninch , 513 U.S. 432, 433-36 (1995)) (footnotes omitted).

33
United States v. Mechanikgreen
scotus · 1986 · cited in 9 Texas opinions naming this issue, 2000–2010
2 sentences

2009Similarly, when determining that a harm analysis focusing on the effect of the alleged error on the grand jury’s decision to indict was appropriate when considering a violation of Rule 6(d) of the Federal Rules of Criminal Procedure, 16 regarding who *506 was properly present during a grand jury proceeding, Justice O’Connor, in a concurring opinion, wrote, “the logical focus of the harmless error inquiry is an examination of the influence of the error on the charging decision.” United States v. Mechanic 475 U.S. 66, 76 , 106 S.Ct. 938, 944 , 89 L.Ed.2d 50 (1986) (Justice O’Connor, joined by Ju

2009Similarly, when determining that a harm analysis focusing on the effect of the alleged error on the grand jury’s decision to indict was appropriate when considering a violation of Rule 6(d) of the Federal Rules of Criminal Procedure, 16 regarding who *506 was properly present during a grand jury proceeding, Justice O’Connor, in a concurring opinion, wrote, “the logical focus of the harmless error inquiry is an examination of the influence of the error on the charging decision.” United States v. Mechanic 475 U.S. 66, 76 , 106 S.Ct. 938, 944 , 89 L.Ed.2d 50 (1986) (Justice O’Connor, joined by Ju

29
Barshaw v. Stategreen
texcrimapp · 2011 · cited in 6 Texas opinions naming this issue, 2012–2021
2 sentences

2021Sandoval, 409 S.W.3d at 288 ; accord Barshaw v. State, 342 S.W.3d 91, 94 (Tex. Crim.

2021Based on our review under the factors used in Coble—three weighing against reversible harm, one in favor, and the other mixed—we are not left with “‘grave doubt’ about whether the result of the trial was free from the substantial influence of the error.” See Sandoval, 409 S.W.3d at 288 ; see also Barshaw, 342 S.W.3d at 94 .

26
O'NEAL v. McAninchgreen
scotus · 1995 · cited in 6 Texas opinions naming this issue, 2006–2015
2 sentences

2015App. 2002) (quoting O’Neal v. McAninch, 513 U.S. 432, 435 , 115 S. Ct. 992, 994 (1995)).

2015App. 2002) (quoting O’Neal v. McAninch, 513 U.S. 432, 435 , 115 S. Ct. 992, 994 (1995)).

26
Felix Sandoval v. Stategreen
texapp · 2013 · cited in 3 Texas opinions naming this issue, 2015–2021
2 sentences

2021Based on our review under the factors used in Coble—three weighing against reversible harm, one in favor, and the other mixed—we are not left with “‘grave doubt’ about whether the result of the trial was free from the substantial influence of the error.” See Sandoval, 409 S.W.3d at 288 ; see also Barshaw, 342 S.W.3d at 94 .

2015App. 2005) (footnotes omitted); accord Sandoval, 409 S.W.3d at 287-88 . [I]f the reviewing court has “a grave doubt” that the result was free from the substantial influence of the error, then it must treat the error as if it did.

23
Kotteakos v. United Statesgreen
scotus · 1946 · cited in 2 Texas opinions naming this issue, 2016–2021
2 sentences

2021Instead, “it is the reviewing court’s duty to assess harm after conducting a proper review of the record to determine the influence the error had in light of all the other evidence.” Id. (citing Kotteakos v. United States, 328 U.S. 750, 762 (1946)).

2016App. 1997); see also Brecht v. Abrahamson, 507 U.S. 619, 638 (1993) (identifying the proper standard as “whether the error ‘had substantial and injurious effect or influence in determining the jury’s verdict”) (quoting Kotteakos v. United States, 328 U.S. 750, 764-65 (1946)). 34 King, 953 S.W.2d at 271 (applying the test adopted by the United States Supreme Court in Kotteakos v. United States (citing Kotteakos, 328 U.S. at 764-65 )). 35 Kotteakos, 328 U.S. at 764 . 36 Id. 37 Burnett v. State, 88 S.W.3d 633, 638 (Tex. Crim.

22
Thomas v. Stategreen
texcrimapp · 2016 · cited in 2 Texas opinions naming this issue, 2020–2020
2 sentences

2020Rather, it is the reviewing court’s duty to assess harm after conducting a proper review of the record to determine the influence the error had in light of all the other evidence.” Thomas v. State, 505 S.W.3d 916, 926 (Tex. Crim.

2020Thomas v. State, 505 S.W.3d 916, 926 (Tex. Crim.

22
King v. Stategreen
texcrimapp · 1997 · cited in 1 Texas opinions naming this issue, 2016–2016
2 sentences

2016If so, or if one is left in grave doubt, the conviction cannot stand.”35 On the other hand, if “the error did not influence the jury, or had but very slight effect, the verdict and the judgment should stand.” 36 Neither Appellant nor the State has any formal burden to show harm or harmlessness under Rule 44.2(b).37 Rather, it is the reviewing court’s duty to assess harm after conducting a proper review of the record to determine the influence the error had in light of all the other evidence.38 designated for publication); Walker v. State, 994 S.W.2d 199, 205 (Tex. App.—Houston [1st Dist.] 1999

2016App. 1997); see also Brecht v. Abrahamson, 507 U.S. 619, 638 (1993) (identifying the proper standard as “whether the error ‘had substantial and injurious effect or influence in determining the jury’s verdict”) (quoting Kotteakos v. United States, 328 U.S. 750, 764-65 (1946)). 34 King, 953 S.W.2d at 271 (applying the test adopted by the United States Supreme Court in Kotteakos v. United States (citing Kotteakos, 328 U.S. at 764-65 )). 35 Kotteakos, 328 U.S. at 764 . 36 Id. 37 Burnett v. State, 88 S.W.3d 633, 638 (Tex. Crim.

11
Brecht v. Abrahamsongreen
scotus · 1993 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016App. 1997); see also Brecht v. Abrahamson, 507 U.S. 619, 638 (1993) (identifying the proper standard as “whether the error ‘had substantial and injurious effect or influence in determining the jury’s verdict”) (quoting Kotteakos v. United States, 328 U.S. 750, 764-65 (1946)). 34 King, 953 S.W.2d at 271 (applying the test adopted by the United States Supreme Court in Kotteakos v. United States (citing Kotteakos, 328 U.S. at 764-65 )). 35 Kotteakos, 328 U.S. at 764 . 36 Id. 37 Burnett v. State, 88 S.W.3d 633, 638 (Tex. Crim.

11
Walker v. Stategreen
texapp · 1999 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016If so, or if one is left in grave doubt, the conviction cannot stand.”35 On the other hand, if “the error did not influence the jury, or had but very slight effect, the verdict and the judgment should stand.” 36 Neither Appellant nor the State has any formal burden to show harm or harmlessness under Rule 44.2(b).37 Rather, it is the reviewing court’s duty to assess harm after conducting a proper review of the record to determine the influence the error had in light of all the other evidence.38 designated for publication); Walker v. State, 994 S.W.2d 199, 205 (Tex. App.—Houston [1st Dist.] 1999

11
Gutierrez-Gomez v. Stategreen
texapp · 2010 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014Id. at 637 ; see also Gutierrez-Gomez, 321 S.W.3d at 682 .

11
Brown v. Stategreen
texapp · 2006 · cited in 1 Texas opinions naming this issue, 2008–2008
1 sentence

2008Mick's argument is based on our opinion in Brown v. State , 189 S.W.3d 382, 387 (Tex. App.--Texarkana 2006, pet. ref'd).

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 (11)

CaseCitedYears
Jordan v. North Mississippi Rural Legal Services, Inc. green
scotus · 1987
2 sentences

2009Similarly, when determining that a harm analysis focusing on the effect of the alleged error on the grand jury’s decision to indict was appropriate when considering a violation of Rule 6(d) of the Federal Rules of Criminal Procedure, (footnote: 16) regarding who was properly present during a grand jury proceeding, Justice O’Connor, in a concurring opinion, wrote, “the logical focus of the harmless error inquiry is an examination of the influence of the error on the charging decision.” United States v. Mechanik, 475 U.S. 66, 76 , 106 S.Ct. 938, 944 , 98 L.Ed.2d 50 (1986) (Justice O’Connor, join

2009Similarly, when determining that a harm analysis focusing on the effect of the alleged error on the grand jury’s decision to indict was appropriate when considering a violation of Rule 6(d) of the Federal Rules of Criminal Procedure,16 regarding who was properly present during a grand jury proceeding, Justice O’Connor, in a concurring opinion, wrote, “the logical focus of the harmless error inquiry is an examination of the influence of the error on the charging decision.” United States v. Mechanik, 475 U.S. 66, 76 , 106 S.Ct. 938, 944 , 98 L.Ed.2d 50 (1986) (Justice O’Connor, joined by Justice

42008–2009
Webb v. State green
texapp · 2005
2 sentences

2021Consequently, although the trial court erred by failing to admonish appellant as required by article 26.13(a), after reviewing the record as a whole, we do not have “grave doubt” about whether appellant’s conviction “was free from the substantial influence of the error.” See Webb, 156 S.W.3d at 656 .

2021Consequently, although the trial court erred by failing to admonish appellant as required by article 26.13(a), after reviewing the record as a whole, we do not have “grave doubt” about whether appellant’s conviction “was free from the substantial influence of the error.” See Webb, 156 S.W.3d at 656 .

22021–2021
Reeves v. State green
texapp · 2003
2 sentences

2009“Grave doubt” means that “in the judge’s mind, the matter is so evenly balanced that he feels himself in virtual equipoise as to the harmlessness of the error.” Thus, “in cases of grave doubt as to harmlessness the petitioner must win.” -9- 04-06-00251-CR, 04-06-00252-CR and 04-06-00253-CR Id. at 795 (quoting Burnett v. State, 88 S.W.3d 633, 637-38 (Tex. Crim.

2009“Grave doubt” means that “in the judge’s mind, the matter is so evenly balanced that he feels himself in virtual equipoise as to the harmlessness of the error.” Thus, “in cases of grave doubt as to harmlessness the petitioner must win.” Id. at 795 {quoting Burnett v. State, 88 S.W.3d 633, 637-38 (Tex.Crim.App.2002) (footnotes omitted)).

22009–2009
Grado, Michael Anthony green
texcrimapp · 2014
1 sentence

2024Grado v. State, No. 07-11-00468-CR, 2013 WL 3355743 , at *5 (Tex. App.—Amarillo June 28, 2013), aff’d, 445 S.W.3d 736 (Tex. Crim.

12024–2024
Wall v. State green
texcrimapp · 2006
1 sentence

2021By contrast, the United States Supreme Court has held that, in constitutional error cases, “the standard of review ‘requir[es] the beneficiary of a constitutional error to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’” Wall v. State, 184 S.W.3d 730 , 746 n.53 (Tex. Crim.

12021–2021
Bank of Nova Scotia v. United States green
scotus · 1988
1 sentence

2008Id.

12008–2008
Shankle v. State green
texapp · 2001
1 sentence

2006In support of his position, he cites Burnett , 88 S.W.3d at 637 B 38; Song Sun Hwang v. State , 130 S.W.3d 496 , 499 B 500 (Tex. App. C Dallas 2004, pet. ref = d); and Shankle v. State , 59 S.W.3d 756 , 761 B 62 (Tex. App. C Austin 2001), vacated on other grounds , 119 S.W.3d 808 (2003).

12006–2006
Song Sun Hwang v. State green
texapp · 2004
1 sentence

2006In support of his position, he cites Burnett , 88 S.W.3d at 637 B 38; Song Sun Hwang v. State , 130 S.W.3d 496 , 499 B 500 (Tex. App. C Dallas 2004, pet. ref = d); and Shankle v. State , 59 S.W.3d 756 , 761 B 62 (Tex. App. C Austin 2001), vacated on other grounds , 119 S.W.3d 808 (2003).

12006–2006
Shankle v. State green
texcrimapp · 2003
1 sentence

2006In support of his position, he cites Burnett , 88 S.W.3d at 637 B 38; Song Sun Hwang v. State , 130 S.W.3d 496 , 499 B 500 (Tex. App. C Dallas 2004, pet. ref = d); and Shankle v. State , 59 S.W.3d 756 , 761 B 62 (Tex. App. C Austin 2001), vacated on other grounds , 119 S.W.3d 808 (2003).

12006–2006
Erdman v. State green
texcrimapp · 1993
2 sentences

2004In her motion to suppress, Woehst relied primarily on Erdman v. State, 861 S.W.2d 890 (Tex.Crim.App.1993). 3 However, Woehst also relied on the effect of the officer’s Transportation Code violation regarding the statutory consequences of refusing a breath test and, particularly, the influence that the violation had on Woehst’s decision to refuse to take the breath test.

2004In her motion to suppress, Woehst relied primarily on Erdman v. State, 861 S.W.2d 890 (Tex.Crim.App.1993). [3] However, Woehst also relied on the effect of the officer's Transportation Code violation regarding the statutory consequences of refusing a breath test and, particularly, the influence that the violation had on Woehst's decision to refuse to take the breath test.

12004–2004
Tate v. State green
· 1895
1 sentence

1927Among them are the following: Tate v. State, 33 S.W.

11927–1927

Statutes the citing opinions construe

TX § Tex. Penal Code § 19.02 (10) TX § Tex. Penal Code § 22.021 (6) TX § Tex. Penal Code § 30.02 (4) TX § Tex. Penal Code § 21.11 (3) TX § Tex. Penal Code § 22.011 (3) TX § Tex. Penal Code § 49.04 (3) USC § 20u.s.c.1232g(b)(2)(a) (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 84 (1927–2025) AL 69 (1847–2015) OH 30 (1982–2024) VA 21 (1896–2024) CA 19 (1965–2024) PA 9 (1996–2026) GA 8 (1990–2024) MO 8 (1860–2017) CO 6 (2010–2024) CT 6 (1988–2019) IA 5 (1939–2021) FL 4 (1927–2023) OR 4 (1915–2019) ND 4 (1994–2020) MS 4 (1994–2008) KS 4 (1994–2011) WV 3 (2013–2020) MN 3 (1986–2014) ID 3 (1993–1994) WA 3 (1997–2010) HI 3 (1930–1989) MT 2 (2008–2015) ME 2 (1984–1985) IL 2 (1986–2006) DE 2 (1987–1993) TN 2 (2001–2006) LA 2 (1921–1950) IN 2 (1999–2004) NM 2 (1973–1975) MD 2 (1940–2007)

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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