per se reversible error (Mississippi) · Go Syfert
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per se reversible error in Mississippi

10 Mississippi opinions name it 2 courts 1998–2009 0 in the last five years

The cases below were cited by Mississippi 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 (2)

CaseFollowedCited
Payton v. Stategreen
miss · 1999 · cited in 7 Mississippi opinions naming this issue, 1998–2007
2 sentences

2007Although the Payton court refused to adopt a per se reversible error rule, it held that "the use of the `send a message' argument may, depending upon the surrounding circumstances, constitute reversible error on its own." Id. at 271 (¶ 14).

2007The Payton court stated, "Standing alone, the district attorney's use of the `send a message' argument in this case would be reversible error because of the prejudice against Payton evidenced by his more severe sentence." Id. at 272 (¶ 15).

67
Rushen v. Spaingreen
scotus · 1983 · cited in 2 Mississippi opinions naming this issue, 2008–2009
2 sentences

2009No Mississippi caselaw was found on whether this constitutes per se reversible error. 1 However, in Rushen v. Spain, 464 U.S. 114, 119 , 104 S.Ct. 453, 456 , 78 L.Ed.2d 267 (1983), the Supreme Court, in a per curiam opinion, held that an unrecorded ex parte communication between the trial judge and a juror can be harmless error, if the prejudicial effect can be adequately determined by a post-trial hearing, so as “to mitigate constitutional error, if any, that has occurred.” Rushen, 464 U.S. at 119-20 , 104 S.Ct. 453 (citations omitted).

2009No Mississippi caselaw was found on whether this constitutes per se reversible error. 1 However, in Rushen v. Spain, 464 U.S. 114, 119 , 104 S.Ct. 453, 456 , 78 L.Ed.2d 267 (1983), the Supreme Court, in a per curiam opinion, held that an unrecorded ex parte communication between the trial judge and a juror can be harmless error, if the prejudicial effect can be adequately determined by a post-trial hearing, so as “to mitigate constitutional error, if any, that has occurred.” Rushen, 464 U.S. at 119-20 , 104 S.Ct. 453 (citations omitted).

12

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Alexander v. State green
missctapp · 1999
2 sentences

2000This Court tempered the holding in Alexanderby adopting Judge Southwick's concurring opinion, Id., at 1065 , and declined to adopt a per se reversible error rule.

1998This Court tempered the holding in Alexander by adopting Judge Southwick's concurring opinion, Id., at 1065 , and declined to adopt a per se reversible error rule.

21998–2000

Where else courts name it

FL 50 (1982–2026) MS 10 (1998–2009) CA 7 (1980–2022) NY 6 (1989–2000) IL 3 (1993–1996) CT 3 (2003–2025) DC 3 (1986–2008) SC 3 (1994–2011) TN 2 (1993–2004) WV 2 (1989–1995)

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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