existence of plain error (Oregon) · Go Syfert
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existence of plain error in Oregon

7 Oregon opinions name it 2 courts 2010–2026 3 in the last five years

The cases below were cited by Oregon 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 (1)

CaseFollowedCited
State v. Lennongreen
or · 2010 · cited in 2 Oregon opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., State v. Lennon, 348 Or 148 , 152 n 2, 229 P3d 589 (2010) (so noting).

2011See, e.g., State v. Lennon, 348 Or 148 , 152 n 2, 229 P3d 589 (2010) (so noting).

22

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Ailes v. Portland Meadows, Inc. green
or · 1991
2 sentences

2025Ailes v. Portland Meadows, Inc., 312 Or 376 , 382 n 6, 823 P2d 956 (1991).

2025Ailes v. Portland Meadows, Inc., 312 Or 376 , 382 n 6, 823 P2d 956 (1991).

32010–2025
State v. Chitwood green
or · 2022
2 sentences

2026The dissenting opin- ion noted that our “cases have left unresolved the question whether a party’s strategic choice not to object is relevant to the existence of plain error, or relevant only to the discretion- ary choice to correct such an error, or both.” Id. at 334 n 2 (Garrett, J., dissenting) (emphasis in original).

2025In arguing otherwise, the state contends that defendant may have made a strategic choice not to object to Williams’s testimony.1 See State v. Fults, 343 Or 515, 523 , 1 As we observe in another case issued this same day, “our recent case law has left unresolved the question whether a party’s strategic choice not to object is relevant to the existence of plain error, or relevant only to the discretionary choice to correct such an error, or both.” State v. Vaninetti, __ Or App __, __, __ P3d __ (2025) (slip op at 8) (citing State v. Chitwood, 370 Or 305 , 334 n 2, 518 P3d 903 Cite as 346 Or App

22025–2026
State v. Wiltse green
or · 2024
1 sentence

2026Finally, we addressed the “strategic choice” issue again in a different context in Wiltse, 373 Or 1 .

12026–2026
cluster 10839828 green
·
1 sentence

2026And in Wiltse, we determined that Cite as 375 Or 132 (2026) 145 whether the defendant had made a strategic choice not to object to a jury instruction was a factor to be considered at step two of the analysis in determining whether a conviction should be reversed based on that plain error.

12026–2026
State v. Fults green
or · 2007
2 sentences

2025In arguing otherwise, the state contends that defendant may have made a strategic choice not to object to Williams’s testimony.1 See State v. Fults, 343 Or 515, 523 , 1 As we observe in another case issued this same day, “our recent case law has left unresolved the question whether a party’s strategic choice not to object is relevant to the existence of plain error, or relevant only to the discretionary choice to correct such an error, or both.” State v. Vaninetti, __ Or App __, __, __ P3d __ (2025) (slip op at 8) (citing State v. Chitwood, 370 Or 305 , 334 n 2, 518 P3d 903 Cite as 346 Or App

2025In arguing otherwise, the state contends that defendant may have made a strategic choice not to object to Williams’s testimony.1 See State v. Fults, 343 Or 515, 523 , 1 As we observe in another case issued this same day, “our recent case law has left unresolved the question whether a party’s strategic choice not to object is relevant to the existence of plain error, or relevant only to the discretionary choice to correct such an error, or both.” State v. Vaninetti, __ Or App __, __, __ P3d __ (2025) (slip op at 8) (citing State v. Chitwood, 370 Or 305 , 334 n 2, 518 P3d 903 Cite as 346 Or App

12025–2025
State v. Arena-Easton neutral
orctapp · 2025
1 sentence

2025In arguing otherwise, the state contends that defendant may have made a strategic choice not to object to Williams’s testimony.1 See State v. Fults, 343 Or 515, 523 , 1 As we observe in another case issued this same day, “our recent case law has left unresolved the question whether a party’s strategic choice not to object is relevant to the existence of plain error, or relevant only to the discretionary choice to correct such an error, or both.” State v. Vaninetti, __ Or App __, __, __ P3d __ (2025) (slip op at 8) (citing State v. Chitwood, 370 Or 305 , 334 n 2, 518 P3d 903 Cite as 346 Or App

12025–2025

Where else courts name it

TN 159 (2000–2026) OH 33 (1993–2026) UT 30 (1993–2020) WI 12 (2007–2026) IL 11 (1978–2017) MO 10 (1990–2014) NC 7 (1986–2014) OR 7 (2010–2026) WY 5 (1991–2022) MI 4 (2003–2016)

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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