structural error (Arkansas) · Go Syfert
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structural error in Arkansas

9 Arkansas opinions name it 2 courts 1996–2026 3 in the last five years

The cases below were cited by Arkansas 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
Reams v. Stategreen
· 2018 · cited in 2 Arkansas opinions naming this issue, 2020–2020
2 sentences

2020See Reams v. State, 2018 Ark. 324 , at 16, 560 S.W.3d 441, 452 (citing McKaskle v. Wiggins, 465 U.S. 168 (1984)).

2020Reams v. State, 2018 Ark. 324 , 560 S.W.3d 441 .

12
McKaskle v. Wigginsgreen
scotus · 1984 · cited in 1 Arkansas opinions naming this issue, 2020–2020
1 sentence

2020See Reams v. State, 2018 Ark. 324 , at 16, 560 S.W.3d 441, 452 (citing McKaskle v. Wiggins, 465 U.S. 168 (1984)).

11
California v. Roygreen
scotus · 1996 · cited in 1 Arkansas opinions naming this issue, 2015–2015
2 sentences

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

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Neder v. United Statesgreen
scotus · 1999 · cited in 1 Arkansas opinions naming this issue, 2015–2015
2 sentences

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

11
United States v. Gonzalez-Lopezgreen
scotus · 2006 · cited in 1 Arkansas opinions naming this issue, 2013–2013
2 sentences

2013Daniels v. State, 2013 Ark. 208 , at 6-7, 2013 WL 2149901 (per curiam) (citing United States v. Gonzalez-Lopez, 548 U.S. 140 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (2006)); see also United States v. Gonzalez-Lopez, 399 F.3d 924, 934 (8th Cir.2005), aff’d and remanded, 548 U.S. 140 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (stating that “the denial of the right to counsel of choice clearly belongs in the class of fundamental constitutional errors which reflect a defect in the framework of the trial mechanism”).

2013Daniels v. State, 2013 Ark. 208 , at 6-7, 2013 WL 2149901 (per curiam) (citing United States v. Gonzalez-Lopez, 548 U.S. 140 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (2006)); see also United States v. Gonzalez-Lopez, 399 F.3d 924, 934 (8th Cir.2005), aff’d and remanded, 548 U.S. 140 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (stating that “the denial of the right to counsel of choice clearly belongs in the class of fundamental constitutional errors which reflect a defect in the framework of the trial mechanism”).

11
United States v. Cuauhtemoc Gonzalez-Lopez, Also Known as Tomasgreen
ca8 · 2005 · cited in 1 Arkansas opinions naming this issue, 2013–2013
1 sentence

2013Daniels v. State, 2013 Ark. 208 , at 6-7, 2013 WL 2149901 (per curiam) (citing United States v. Gonzalez-Lopez, 548 U.S. 140 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (2006)); see also United States v. Gonzalez-Lopez, 399 F.3d 924, 934 (8th Cir.2005), aff’d and remanded, 548 U.S. 140 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (stating that “the denial of the right to counsel of choice clearly belongs in the class of fundamental constitutional errors which reflect a defect in the framework of the trial mechanism”).

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Distinguished, questioned or overruled (1)

CaseNegativeCited
Sullivan v. Louisianagreen
scotus · 1993 · cited in 1 Arkansas opinions naming this issue, 2015–2015
2 sentences

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

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Also cited on this issue (7)

CaseCitedYears
Teater v. State green
arkctapp · 2005
2 sentences

2022App. 215 , 201 S.W.3d 442 (2005), without analysis or explanation, Gay asserts that a deficient jury instruction amounts to a structural error.

2022App. 215 , 201 S.W.3d 442 (2005), without analysis or explanation, Gay asserts that a deficient jury instruction amounts to a structural error.

22022–2022
McCoy v. Louisiana green
scotus · 2018
1 sentence

2026Citing McCoy 18 v. Louisiana, 584 U.S. 414 (2018), Holly argues that this deprivation amounts to a structural error and that no demonstration of prejudice is required.

12026–2026
Faretta v. California green
scotus · 1975
1 sentence

2020Faretta, supra. Importantly, the denial of the right to self-representation is not subject to a harmless-error analysis because it is deemed a structural error.

12020–2020
Lilly v. State green
texcrimapp · 2012
1 sentence

2016Lilly, 365 S.W.3d at 328 .

12016–2016
Sasser v. State green
ark · 1999
2 sentences

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

2015See Neder v. United States, 527 U.S. 1 , 119 S.Ct. 1827 , 144 L.Ed.2d 35 (1999) (applying the harmless-error analysis to an instruction that omitted the materiality element of a tax offense); see also California v. Roy, 519 U.S. 2 , 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996) (per curiam) (applying the harmless-error analysis |Bto an instruction that failed to instruct the jury that it could convict the defendant as an aider and abettor only if it found that the defendant had the “intent or purpose” of aiding the confederate’s crime); Sasser v. State, 338 Ark. 375 , 993 S.W.2d 901 (1999) (holding t

12015–2015
Springs v. State green
ark · 2012
1 sentence

2013Springs, supra; Sasser, supra. Erroneous deprivation of the right to counsel of choice is a structural error.

12013–2013
United States v. Gaudin green
scotus · 1995
1 sentence

1996Hall petitions for rehearing and cites U.S. v. Gaudin, _ U.S. _, 115 S.Ct. 2310 (1995), for the proposition that our decision improperly failed to entertain the jury-instruction issue raised herein as a structural error.

11996–1996

Statutes the citing opinions construe

AR § Ark. Code Ann. § 5-4-604 (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

IL 265 (1974–2026) OH 250 (1996–2026) CA 178 (1995–2026) MI 171 (1994–2026) TX 157 (1996–2026) WA 152 (2002–2025) PA 96 (2003–2026) OR 86 (1992–2024) CO 73 (1995–2026) LA 70 (1993–2026) IA 65 (2003–2026) MA 55 (1995–2025) NC 46 (2002–2025) KY 45 (2005–2026) AZ 44 (1996–2026) MN 41 (2001–2026) MT 41 (2001–2026) KS 40 (2001–2026) WI 36 (2003–2025) CT 32 (1996–2026) MD 29 (2001–2026) NV 28 (2001–2021) DC 26 (1997–2025) NM 26 (2004–2025) MO 25 (2002–2024) GA 25 (2007–2025) UT 24 (1996–2026) NJ 23 (1992–2026) ND 21 (2004–2025) TN 19 (2006–2025) ID 16 (2003–2023) FL 15 (1995–2023) SD 13 (2000–2025) WY 12 (2008–2025) SC 12 (1995–2025) OK 12 (1997–2022) AL 11 (1999–2024) VA 10 (2005–2026) HI 10 (2013–2025) NE 10 (1999–2026) ME 9 (2001–2026) AR 9 (1996–2026) IN 8 (2002–2025) AK 6 (2018–2025) VT 6 (1995–2026) DE 6 (2003–2025) NY 5 (1939–2012) VI 4 (2013–2026) GU 3 (2022–2025) MS 3 (2013–2023) NH 3 (2009–2013)

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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