Chapman rule (Washington) · Go Syfert
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Chapman rule in Washington

7 Washington opinions name it 2 courts 1980–2018 0 in the last five years

The cases below were cited by Washington 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 (3)

CaseFollowedCited
State v. Mendezred
wash · 1999 · cited in 2 Washington opinions naming this issue, 2009–2009
2 sentences

2009See Mendez, 137 Wn.2d at 220 . ¶20 The second distinction is that, although Chapman may have relied on the van driver’s resembling a general description of the van’s registered owner, unlike the situation in Lambert , here (1) there was no evidence that distinguished the person Chapman saw driving the van from the registered owner’s description, on which he relied; and (2) because the arrest warrants were for the registered owner of the van that he observed, there were direct connections among the van, the owner’s description, the suspected criminal activity, and the driver. ¶21 We hold, there

2009See Mendez, 137 Wash.2d at 220 , 970 P.2d 722 . ¶ 20 The second distinction is that, although Chapman may have relied on the van driver's resembling a general description of the van's registered owner, unlike the situation in Lambert , here (1) there was no evidence that distinguished the person Chapman saw driving the van from the registered owner's description, on which he relied; and (2) because the arrest warrants were for the registered owner of the van that he observed, there were direct connections among the van, the owner's description, the suspected criminal activity, and the driver.

22
State v. Bartelsgreen
wash · 1989 · cited in 1 Washington opinions naming this issue, 2017–2017
1 sentence

2017E.g., Bartels, 112 Wn.2d at 890 (explicitly applying Chapman standard to the category of indigent defendants most likely 13 State V.

11
State v. Mendezred
wash · 1999 · cited in 1 Washington opinions naming this issue, 2009–2009
1 sentence

2009See Mendez, 137 Wash.2d at 220 , 970 P.2d 722 . ¶ 20 The second distinction is that, although Chapman may have relied on the van driver's resembling a general description of the van's registered owner, unlike the situation in Lambert , here (1) there was no evidence that distinguished the person Chapman saw driving the van from the registered owner's description, on which he relied; and (2) because the arrest warrants were for the registered owner of the van that he observed, there were direct connections among the van, the owner's description, the suspected criminal activity, and the driver.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
State v. Stephens green
wash · 1980
2 sentences

1981In a recent case we cited Chapman's rule that a constitutional error must be harmless beyond a reasonable doubt, and refused to hold the error harmless because the court was unable to conclude that the error "`in no way affected the final outcome of the case.'" State v. Stephens, 93 Wn.2d 186, 191 , 607 P.2d 304 (1980).

1981In a recent case we cited Chapman's rule that a constitutional error must be harmless beyond a reasonable doubt, and refused to hold the error harmless because the court was unable to conclude that the error "`in no way affected the final outcome of the case.'" State v. Stephens, 93 Wn.2d 186, 191 , 607 P.2d 304 (1980).

21980–1981
State v. Coristine green
wash · 2013
2 sentences

2018Coristine, 177 Wash.2d at 383 , 300 P.3d 400 .

2018Coristine, 177 Wash.2d at 383 , 300 P.3d 400 .

12018–2018
State v. O'Hara green
wash · 2009
2 sentences

2011App. at 185-87 (quoting State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009)). ¶13 If an appellant successfully shows that the error is both constitutional in magnitude and “manifest,” in that it had practical and identifiable consequences below, the burden then shifts to the State “to prove that the error was harmless . . . under the Chapman standard” 9 beyond a reasonable doubt.

2011App. at 185-87 (quoting State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009)). ¶13 If an appellant successfully shows that the error is both constitutional in magnitude and “manifest,” in that it had practical and identifiable consequences below, the burden then shifts to the State “to prove that the error was harmless . . . under the Chapman standard” 9 beyond a reasonable doubt.

12011–2011
State v. O'HARA green
wash · 2009
2 sentences

2011App. at 185-87 (quoting State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009)). ¶13 If an appellant successfully shows that the error is both constitutional in magnitude and “manifest,” in that it had practical and identifiable consequences below, the burden then shifts to the State “to prove that the error was harmless . . . under the Chapman standard” 9 beyond a reasonable doubt.

2011App. at 185-87 (quoting State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009)). ¶13 If an appellant successfully shows that the error is both constitutional in magnitude and “manifest,” in that it had practical and identifiable consequences below, the burden then shifts to the State “to prove that the error was harmless . . . under the Chapman standard” 9 beyond a reasonable doubt.

12011–2011
Harrington v. California red
scotus · 1969
2 sentences

1980The next year, in Harrington v. California, 395 U.S. 250 , 23 L.Ed.2d 284 , 89 S.Ct. 1726 (1969), the court referred specifically to the Chapman rule and affirmed it, but with reference to overwhelming evidence of guilt.

1980The next year, in Harrington v. California, 395 U.S. 250 , 23 L.Ed.2d 284 , 89 S.Ct. 1726 (1969), the court referred specifically to the Chapman rule and affirmed it, but with reference to overwhelming evidence of guilt.

11980–1980
State v. Burri green
wash · 1976
2 sentences

1980State v. Stephens, 93 Wn.2d 186, 191 , 607 P.2d 304 (1980), citing from State v. Burri, 87 Wn.2d 175 , 550 P.2d 507 (1976).

1980State v. Stephens, 93 Wn.2d 186, 191 , 607 P.2d 304 (1980), citing from State v. Burri, 87 Wn.2d 175 , 550 P.2d 507 (1976).

11980–1980
State v. MacK green
wash · 1971
2 sentences

1980However, the court quoted from the Supreme Court's opinion in State v. Mack, 80 Wn.2d 19 , 490 P.2d 1303 (1971), in which it referred to State v. Martin, supra , *814 which omitted mention of the Chapman rule.

1980However, the court quoted from the Supreme Court's opinion in State v. Mack, 80 Wn.2d 19 , 490 P.2d 1303 (1971), in which it referred to State v. Martin, supra , *814 which omitted mention of the Chapman rule.

11980–1980
State v. Spencer green
washctapp · 1973
2 sentences

1980The court also stated that it was unable to find a distinction in the rule expressed in State v. Martin, supra, and Chapman v. California, supra. In State v. Spencer, 9 Wn.

1980The court also stated that it was unable to find a distinction in the rule expressed in State v. Martin, supra, and Chapman v. California, supra. In State v. Spencer, 9 Wn.

11980–1980

Where else courts name it

CA 874 (1967–2026) DC 51 (1978–2025) LA 43 (1982–2024) TX 42 (1876–2025) MS 26 (1991–2018) ID 24 (1981–2020) NY 15 (2013–2024) WY 14 (1981–2015) TN 13 (1993–2025) WI 13 (1977–2008) KS 13 (2001–2026) IL 13 (1970–2025) OH 10 (1968–2020) AK 10 (1969–2014) AR 9 (1987–2023) GA 8 (1976–2025) PA 8 (1967–2024) IN 7 (1975–2013) MI 7 (1980–2022) WA 7 (1980–2018) FL 7 (1987–2016) MD 7 (1974–2022) NV 6 (1970–2008) AL 5 (1992–2015) VA 5 (1991–2023) ND 5 (1975–1986) CO 4 (1972–2025) CT 4 (1988–2021) NJ 4 (1968–2005) UT 4 (2003–2025) MA 4 (1978–2018) NE 3 (1988–2020) KY 3 (1969–2008) MO 3 (1985–2011) OR 3 (1981–2020) IA 3 (1991–2016) NM 3 (2004–2009) AZ 2 (1970–1996) MT 2 (1980–1995) OK 2 (2025–2025) SC 2 (1969–1980) MN 2 (1951–2002) ME 2 (1973–1988) DE 2 (2000–2025)

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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