reaffirmed principle (Utah) · Go Syfert
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reaffirmed principle in Utah

7 Utah opinions name it 2 courts 1933–2023 1 in the last five years

The cases below were cited by Utah 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
Sheppard v. Geneva Rockgreen
utah · 2021 · cited in 1 Utah opinions naming this issue, 2023–2023
1 sentence

2023There, the court reaffirmed the standard it had set forth in Bowman v. Kalm, 2008 UT 9 , 179 P.3d 754 , namely that expert testimony is not necessarily required to prove that a particular injury caused certain damages when the link between injury and treatment “would be clear to a lay juror who has no medical training—i.e., when the causal connection is readily apparent using only common knowledge.” Sheppard, 2021 UT 31, ¶ 31 (quotation simplified); see Bowman, 2008 UT 9, ¶ 9 .

11
Bowman v. Kalmgreen
utah · 2008 · cited in 1 Utah opinions naming this issue, 2023–2023
2 sentences

2023There, the court reaffirmed the standard it had set forth in Bowman v. Kalm, 2008 UT 9 , 179 P.3d 754 , namely that expert testimony is not necessarily required to prove that a particular injury caused certain damages when the link between injury and treatment “would be clear to a lay juror who has no medical training—i.e., when the causal connection is readily apparent using only common knowledge.” Sheppard, 2021 UT 31, ¶ 31 (quotation simplified); see Bowman, 2008 UT 9, ¶ 9 .

2023There, the court reaffirmed the standard it had set forth in Bowman v. Kalm, 2008 UT 9 , 179 P.3d 754 , namely that expert testimony is not necessarily required to prove that a particular injury caused certain damages when the link between injury and treatment “would be clear to a lay juror who has no medical training—i.e., when the causal connection is readily apparent using only common knowledge.” Sheppard, 2021 UT 31, ¶ 31 (quotation simplified); see Bowman, 2008 UT 9, ¶ 9 .

11
State v. McGeegreen
utah · 1970 · cited in 1 Utah opinions naming this issue, 2015–2015
2 sentences

2015Seq, e.g., State v. Martinez, 23 Utah 2d 62 , 457 P.2d 613, 614 (1969) (first instance of this court applying Chapman, concluding that alleged Miranda and Fourth Amendment violations were harmless beyond a reasonable doubt); State v. McGee, 24 Utah 2d 396 , 473 P.2d 388, 391 (1970) (applying the standard without citing to authority).

2015Seq, e.g., State v. Martinez, 23 Utah 2d 62 , 457 P.2d 613, 614 (1969) (first instance of this court applying Chapman, concluding that alleged Miranda and Fourth Amendment violations were harmless beyond a reasonable doubt); State v. McGee, 24 Utah 2d 396 , 473 P.2d 388, 391 (1970) (applying the standard without citing to authority).

11
State v. Martinezgreen
utah · 1969 · cited in 1 Utah opinions naming this issue, 2015–2015
2 sentences

2015Seq, e.g., State v. Martinez, 23 Utah 2d 62 , 457 P.2d 613, 614 (1969) (first instance of this court applying Chapman, concluding that alleged Miranda and Fourth Amendment violations were harmless beyond a reasonable doubt); State v. McGee, 24 Utah 2d 396 , 473 P.2d 388, 391 (1970) (applying the standard without citing to authority).

2015Seq, e.g., State v. Martinez, 23 Utah 2d 62 , 457 P.2d 613, 614 (1969) (first instance of this court applying Chapman, concluding that alleged Miranda and Fourth Amendment violations were harmless beyond a reasonable doubt); State v. McGee, 24 Utah 2d 396 , 473 P.2d 388, 391 (1970) (applying the standard without citing to authority).

11
Kimball Laundry Co. v. United Statesgreen
scotus · 1949 · cited in 1 Utah opinions naming this issue, 1995–1995
2 sentences

1995The Court held in Kimball Laundry Co. v. United States, 338 U.S. 1, 11, 15-16 , 69 S.Ct. 1434, 1442-43 , 93 L.Ed. 1765 (1948), that a governmental taking of a laundry’s intangible “trade routes,” meaning customer lists and continued patronage, required just compensation.

1995The Court held in Kimball Laundry Co. v. United States, 338 U.S. 1, 11, 15-16 , 69 S.Ct. 1434, 1442-43 , 93 L.Ed. 1765 (1948), that a governmental taking of a laundry’s intangible “trade routes,” meaning customer lists and continued patronage, required just compensation.

11
Berry by and Through Berry v. Beech Aircraftgreen
utah · 1985 · cited in 1 Utah opinions naming this issue, 1987–1987
1 sentence

1987Berry v. Beech Aircraft Corp., 717 P.2d 670, 676 (Utah 1985); see also 16A C.J.S.

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Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Delaware v. Van Arsdall green
scotus · 1986
2 sentences

2015And the Court reaffirmed this principle in Delo-ware v. Van Arsdall with language this court has often employed: "[AJn otherwise valid conviction should not be set aside if the reviewing court may confidently say, on the whole record, that the constitutional error was harmless beyond a reasonable doubt." 475 U.S. 673, 681 , 106 S.Ct. 1431 , 89 L.Ed.2d 674 (1986). 138 Neither Chapman nor Van Arsdall specified whether this federal standard applies with equal force to preserved and un-preserved trial errors, and we acknowledge that our precedent on this issue has not been consistent. 10 In the ye

2015And the Court reaffirmed this principle in Delo-ware v. Van Arsdall with language this court has often employed: "[AJn otherwise valid conviction should not be set aside if the reviewing court may confidently say, on the whole record, that the constitutional error was harmless beyond a reasonable doubt." 475 U.S. 673, 681 , 106 S.Ct. 1431 , 89 L.Ed.2d 674 (1986). 138 Neither Chapman nor Van Arsdall specified whether this federal standard applies with equal force to preserved and un-preserved trial errors, and we acknowledge that our precedent on this issue has not been consistent. 10 In the ye

12015–2015
Payton v. New York green
scotus · 1980
2 sentences

1986The Court therefore reaffirmed the rule that all that is required is that there be “ ‘probable cause to associate the property with criminal activity.’ ” Id. at 741-42 , 103 S.Ct. at 1543 (quoting Payton v. New York, 445 U.S. 573, 587 , 100 S.Ct. 1371, 1380 , 63 L.Ed.2d 639 (1980)).

1986The Court therefore reaffirmed the rule that all that is required is that there be “ ‘probable cause to associate the property with criminal activity.’ ” Id. at 741-42 , 103 S.Ct. at 1543 (quoting Payton v. New York, 445 U.S. 573, 587 , 100 S.Ct. 1371, 1380 , 63 L.Ed.2d 639 (1980)).

11986–1986
Brinegar v. United States green
scotus · 1949
2 sentences

1986Under that standard, an officer must only have a reasonable belief “that certain items may be contraband or stolen property or useful as evidence of a crime; it does not demand any showing that such a belief be correct....” A ‘practical, nontechnical’ probability that incriminating evidence is involved is all that is required.” Brown, 460 U.S. at 742 , 103 S.Ct. at 1543 (quoting Brinegar v. United States, 338 U.S. 160, 176 , 69 S.Ct. 1302, 1311 , 93 L.Ed. 1879 (1949)).

1986Under that standard, an officer must only have a reasonable belief “that certain items may be contraband or stolen property or useful as evidence of a crime; it does not demand any showing that such a belief be correct....” A ‘practical, nontechnical’ probability that incriminating evidence is involved is all that is required.” Brown, 460 U.S. at 742 , 103 S.Ct. at 1543 (quoting Brinegar v. United States, 338 U.S. 160, 176 , 69 S.Ct. 1302, 1311 , 93 L.Ed. 1879 (1949)).

11986–1986
In re Flint green
utah · 1903
2 sentences

1986After statehood, this Court reaffirmed that principle in In re Flint, 25 Utah 338 , 71 P. 531 (1903), and Mutart v. Pratt, 51 Utah 246 , 170 P. 67 (1917).

1986After statehood, this Court reaffirmed that principle in In re Flint, 25 Utah 338 , 71 P. 531 (1903), and Mutart v. Pratt, 51 Utah 246 , 170 P. 67 (1917).

11986–1986
Mutart v. Pratt green
· 1917
2 sentences

1986After statehood, this Court reaffirmed that principle in In re Flint, 25 Utah 338 , 71 P. 531 (1903), and Mutart v. Pratt, 51 Utah 246 , 170 P. 67 (1917).

1986After statehood, this Court reaffirmed that principle in In re Flint, 25 Utah 338 , 71 P. 531 (1903), and Mutart v. Pratt, 51 Utah 246 , 170 P. 67 (1917).

11986–1986
Texas v. Brown green
scotus · 1983
2 sentences

1986The Court therefore reaffirmed the rule that all that is required is that there be “ ‘probable cause to associate the property with criminal activity.’ ” Id. at 741-42 , 103 S.Ct. at 1543 (quoting Payton v. New York, 445 U.S. 573, 587 , 100 S.Ct. 1371, 1380 , 63 L.Ed.2d 639 (1980)).

1986The Court therefore reaffirmed the rule that all that is required is that there be “ ‘probable cause to associate the property with criminal activity.’ ” Id. at 741-42 , 103 S.Ct. at 1543 (quoting Payton v. New York, 445 U.S. 573, 587 , 100 S.Ct. 1371, 1380 , 63 L.Ed.2d 639 (1980)).

11986–1986
Cullen v. Harris neutral
utah · 1903
2 sentences

1933In the case of Cullen v. Harris et al., 27 Utah 4 , 73 P. 1048 , this court reaffirmed the doctrine that an order denying the motion to correct a judgment may be reviewed on appeal from the judgment if properly preserved in the record: “The respondents contend that this appeal should be dismissed for the reason that the order appealed from is not a final judgment.

1933In the case of Cullen v. Harris et al., 27 Utah 4 , 73 P. 1048 , this court reaffirmed the doctrine that an order denying the motion to correct a judgment may be reviewed on appeal from the judgment if properly preserved in the record: “The respondents contend that this appeal should be dismissed for the reason that the order appealed from is not a final judgment.

11933–1933

Where else courts name it

CA 49 (1924–2023) IL 45 (1911–2021) TX 45 (1928–2023) PA 35 (1953–2025) AL 27 (1891–2025) NJ 24 (1938–2021) FL 24 (1940–2018) NY 23 (1876–2016) OH 22 (1954–2026) MS 19 (1932–2026) NC 17 (1930–2022) MD 17 (1911–2019) OK 16 (1905–2007) OR 15 (1967–2022) CT 14 (1983–2011) KY 14 (1931–2022) AR 13 (1845–2004) IN 13 (1939–2020) WI 12 (1948–2010) VA 12 (1936–2019) MI 11 (1915–2020) LA 11 (1924–2025) TN 11 (1930–2010) NE 11 (1946–1997) MO 11 (1887–2020) AZ 10 (1937–2025) WA 10 (1910–2022) SC 9 (1913–2023) KS 9 (1991–2013) MT 8 (1952–2009) DC 8 (1893–2021) MA 7 (1975–2015) NM 7 (1896–1998) UT 7 (1933–2023) HI 7 (1983–2015) ID 6 (1966–2015) GA 6 (1925–1986) CO 6 (1972–2010) WV 5 (1993–2016) MN 5 (1943–1987) RI 5 (1983–2009) WY 4 (1976–2018) NV 4 (1953–2024) ME 3 (1944–1976) IA 3 (1929–1935) DE 3 (1985–2022) SD 3 (1910–1991) ND 2 (1903–1942) NH 2 (1972–1991)

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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