finding of plain error (North Carolina) · Go Syfert
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finding of plain error in North Carolina

11 North Carolina opinions name it 2 courts 1994–2022 2 in the last five years

The cases below were cited by North Carolina 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 (6)

CaseFollowedCited
Tyndall Ex Rel. Tyndall v. Harvey C. Hines Co.green
nc · 1946 · cited in 2 North Carolina opinions naming this issue, 2022–2022
2 sentences

2022Although this Court has held that the opinions of law enforcement officers can carry great weight with the members of a jury, Tyndall, 226 N.C. at 623 (stating that “[t]he witness was a State [highway patrolman] whose duty it was to make a disinterested and impartial investigation” and whose “testimony should, and no doubt did, carry great weight with the jury”), that fact alone does not suffice to necessitate a finding of plain error in this case given the strength of the State’s case against defendant.

2022Although this Court has held that the opinions of law enforcement officers can carry great weight with the members of a jury, Tyndall, 226 N.C. at 623 (stating that “[t]he witness was a State [highway patrolman] whose duty it was to make a disinterested and impartial investigation” and whose “testimony should, and no doubt did, carry great weight with the jury”), that fact alone does not suffice to necessitate a finding of plain error in this case given the strength of the State’s case against defendant.

22
State v. Alexandergreen
nc · 1994 · cited in 1 North Carolina opinions naming this issue, 2012–2012
2 sentences

2012See State v. Elmore, 337 N.C. 789, 792-93 , 448 S.E.2d 501, 502-03 (1994) (holding error harmless beyond a reasonable doubt where a federal agent testified that the defendant said he wanted to consult with an attorney before talking about the matter; and noting that the violation, if any, was de minimis, that the statement was not solicited by the prosecutor, and that the prosecutor did not cross-examine the defendant about exercising his right to remain silent, nor did he refer to the statement in closing arguments); State v. Alexander, 337 N.C. 182, 196 , 446 S.E.2d 83, 91 (1994) (holding no

2012See State v. Elmore, 337 N.C. 789, 792-93 , 448 S.E.2d 501, 502-03 (1994) (holding error harmless beyond a reasonable doubt where a federal agent testified that the defendant said he wanted to consult with an attorney before talking about the matter; and noting that the violation, if any, was de minimis, that the statement was not solicited by the prosecutor, and that the prosecutor did not cross-examine the defendant about exercising his right to remain silent, nor did he refer to the statement in closing arguments); State v. Alexander, 337 N.C. 182, 196 , 446 S.E.2d 83, 91 (1994) (holding no

11
State v. Elmoregreen
· 1994 · cited in 1 North Carolina opinions naming this issue, 2012–2012
2 sentences

2012See State v. Elmore, 337 N.C. 789, 792-93 , 448 S.E.2d 501, 502-03 (1994) (holding error harmless beyond a reasonable doubt where a federal agent testified that the defendant said he wanted to consult with an attorney before talking about the matter; and noting that the violation, if any, was de minimis, that the statement was not solicited by the prosecutor, and that the prosecutor did not cross-examine the defendant about exercising his right to remain silent, nor did he refer to the statement in closing arguments); State v. Alexander, 337 N.C. 182, 196 , 446 S.E.2d 83, 91 (1994) (holding no

2012See State v. Elmore, 337 N.C. 789, 792-93 , 448 S.E.2d 501, 502-03 (1994) (holding error harmless beyond a reasonable doubt where a federal agent testified that the defendant said he wanted to consult with an attorney before talking about the matter; and noting that the violation, if any, was de minimis, that the statement was not solicited by the prosecutor, and that the prosecutor did not cross-examine the defendant about exercising his right to remain silent, nor did he refer to the statement in closing arguments); State v. Alexander, 337 N.C. 182, 196 , 446 S.E.2d 83, 91 (1994) (holding no

11
State v. Ferebeegreen
ncctapp · 2006 · cited in 1 North Carolina opinions naming this issue, 2009–2009
2 sentences

2009“Where a defendant fails to make a proper objection at trial, he waives the issue on appeal, absent a finding of plain error.” State v. Ferebee, 177 N.C.

2009App. 785, 789 , 630 S.E.2d 460, 463 (2006) (citations omitted).

11
State v. McNeilgreen
nc · 1999 · cited in 1 North Carolina opinions naming this issue, 2006–2006
2 sentences

2006State v. McNeil, 350 N.C. 657, 691 , 518 S.E.2d 486, 507 (1999).

2006State v. McNeil, 350 N.C. 657, 691 , 518 S.E.2d 486, 507 (1999).

11
State v. Holdergreen
nc · 1992 · cited in 1 North Carolina opinions naming this issue, 1995–1995
2 sentences

1995The trial court gave the substance of the instruction defendant requested. “[W]hen a request is made for a specific instruction that is supported by the evidence and is a correct statement of the law, the court, although not required to give the requested instruction verbatim, must charge the jury in substantial conformity therewith.” State v. Holder, 331 N.C. 462, 474 , 418 S.E.2d 197, 203 (1992).

1995The trial court gave the substance of the instruction defendant requested. “[W]hen a request is made for a specific instruction that is supported by the evidence and is a correct statement of the law, the court, although not required to give the requested instruction verbatim, must charge the jury in substantial conformity therewith.” State v. Holder, 331 N.C. 462, 474 , 418 S.E.2d 197, 203 (1992).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
State v. Lawrence green
nc · 2012
2 sentences

2018ANALYSIS A. Jury Instructions At trial, Defendant failed to object to the instructions regarding the charge of felonious child abuse by sexual act in violation of N.C.G.S. § 14-318.4(a2) (1991). 4 Therefore, the trial court's decision will only be overturned upon a finding of plain error. *587 State v. Lawrence , 365 N.C. 506 , 516, 723 S.E.2d 326 , 333 (2012). "[T]he North Carolina plain error standard of review [for jury instructions] applies only when the alleged error is unpreserved[.]" Id.

2018ANALYSIS A. Jury Instructions At trial, Defendant failed to object to the instructions regarding the charge of felonious child abuse by sexual act in violation of N.C.G.S. § 14-318.4(a2) (1991). 4 Therefore, the trial court's decision will only be overturned upon a finding of plain error. *587 State v. Lawrence , 365 N.C. 506 , 516, 723 S.E.2d 326 , 333 (2012). "[T]he North Carolina plain error standard of review [for jury instructions] applies only when the alleged error is unpreserved[.]" Id.

22016–2018
State v. Jordan green
nc · 1993
2 sentences

2018"Under the plain error rule, defendant must convince this Court not only that there was error, but that absent the error, the jury probably would have reached a different result." State v. Jordan , 333 N.C. 431 , 440, 426 S.E.2d 692 , 697 (1993).

2018"Under the plain error rule, defendant must convince this Court not only that there was error, but that absent the error, the jury probably would have reached a different result." State v. Jordan , 333 N.C. 431 , 440, 426 S.E.2d 692 , 697 (1993).

12018–2018
State v. Moore green
nc · 2012
1 sentence

2013Moore, _ N.C. at _, 726 S.E.2d at 173 -74 (quoting Black, 308 N.C. at 741 , 303 S.E.2d at 807 ) (other citations omitted).

12013–2013
State v. Black green
nc · 1983
2 sentences

2013Moore, _ N.C. at _, 726 S.E.2d at 173 -74 (quoting Black, 308 N.C. at 741 , 303 S.E.2d at 807 ) (other citations omitted).

2013Moore, _ N.C. at _, 726 S.E.2d at 173 -74 (quoting Black, 308 N.C. at 741 , 303 S.E.2d at 807 ) (other citations omitted).

12013–2013
State v. Reid green
nc · 1988
2 sentences

2011Reid, 322 N.C. at 313 , 367 S.E.2d at 674 .

2011Reid, 322 N.C. at 313 , 367 S.E.2d at 674 .

12011–2011
State v. Odom green
nc · 1983
1 sentence

1994Id. at 661, 300 S.E.2d at 378 .

11994–1994

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 8C-1 (6) NC § N.C. Gen. Stat. § 15A-1443 (4)

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

OH 104 (1987–2026) WY 34 (1984–2026) AL 26 (1987–2025) VT 17 (1990–2026) TN 16 (1999–2022) CO 15 (1984–2026) GA 14 (2014–2025) AK 14 (1981–2015) DC 12 (1978–2018) MS 12 (1999–2023) NC 11 (1994–2022) MO 10 (1986–2023) UT 10 (1989–2012) IL 9 (1985–2024) DE 6 (2020–2025) CT 4 (1986–2025) NJ 4 (1963–2024) OK 4 (1997–2022) NE 3 (2015–2024) OR 2 (2007–2011) MI 2 (2020–2022) NV 2 (1997–2026) MN 2 (2001–2017)

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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