Henderson plea in Arizona

6 Arizona opinions name it 2 courts 1978–2023 1 in the last five years

The cases below were cited by Arizona 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 (7)

Case	Followed	Cited
Crystal E. v. Department of Child Safetygreen arizctapp · 2017 · cited in 1 Arizona opinions naming this issue, 2017–2017 1 sentence 2017See Crystal E. v. Dep’t of Child Safety, 241 Ariz. 576, 578, ¶ 6 (App. 2017) (court of appeals generally does not sua sponte address issues not raised by the appellants). 4 WHILES, et al. v. HENDERSON Decision of the Court within two years of the date he resigned as co-trustee.	1	1
Wells Fargo Bank, N.A. v. Allengreen arizctapp · 2012 · cited in 1 Arizona opinions naming this issue, 2017–2017 1 sentence 2017Wells Fargo Bank, N.A. v. Allen, 231 Ariz. 209, 213, ¶ 17 (App. 2012). ¶17 There is no such evidence here; indeed, Henderson’s motion offered no evidence at all to refute Appellants’ conspiracy allegations.	1	1
Doyle v. Ohiogreen scotus · 1976 · cited in 1 Arizona opinions naming this issue, 2017–2017 1 sentence 2017Doyle v. Ohio, 426 U.S. 610, 617 (1976). ¶17 First, Henderson has not shown that the trial court abused its discretion by denying Henderson’s motion for mistrial after the officer’s first statement that Henderson stated that he had “messed up.” Henderson did not initially object to the testimony.	1	1
State v. Daltongreen arizctapp · 2016 · cited in 1 Arizona opinions naming this issue, 2016–2016 2 sentences 2016Applying this standard, we agree with the dissent below that Dalton failed to carry his burden of showing prejudice. 239 Ariz. at 81 ¶ 28, 83 ¶ 41, 366 P.3d at 140, 142 (Cattani, J., dissenting). ¶ 19 Contrary to the court of appeals majority’s conclusion, we find that some of the trial court’s “other instructions to the jury ameliorated the failure to instruct the jury it was required to begin its deliberations anew when the alternate joined it.” Dalton, 239 Ariz. at 78 ¶ 10, 366 P.3d at 137 . 2016Applying this standard, we agree with the dissent below that Dalton failed to carry his burden of showing prejudice. 239 Ariz. at 81 ¶ 28, 83 ¶ 41, 366 P.3d at 140, 142 (Cattani, J., dissenting). ¶ 19 Contrary to the court of appeals majority’s conclusion, we find that some of the trial court’s “other instructions to the jury ameliorated the failure to instruct the jury it was required to begin its deliberations anew when the alternate joined it.” Dalton, 239 Ariz. at 78 ¶ 10, 366 P.3d at 137 .	1	1
State v. Guytangreen arizctapp · 1998 · cited in 1 Arizona opinions naming this issue, 2016–2016 2 sentences 2016Although Guytan addressed Rule 18.5(h) error and aptly explains the potential risks of juror substitution after deliberations have commenced, 192 Ariz. at 518 ¶ 11, 521 ¶¶ 21-22, 968 P.2d at 591, 594 , Guytan pre-dated Henderson and did not clearly articulate the standard of review it applied in finding no “reversible error” in that case, id. at 521 ¶¶ 21-24, 968 P.2d at 594 . ¶ 18 Under Henderson’s error-specific approach, Dalton must show that the trial court’s failure to instruct the reconstituted jury to begin deliberations anew denied him a deliberative, impartial, unanimous jury verdict, 2016Although Guytan addressed Rule 18.5(h) error and aptly explains the potential risks of juror substitution after deliberations have commenced, 192 Ariz. at 518 ¶ 11, 521 ¶¶ 21-22, 968 P.2d at 591, 594 , Guytan pre-dated Henderson and did not clearly articulate the standard of review it applied in finding no “reversible error” in that case, id. at 521 ¶¶ 21-24, 968 P.2d at 594 . ¶ 18 Under Henderson’s error-specific approach, Dalton must show that the trial court’s failure to instruct the reconstituted jury to begin deliberations anew denied him a deliberative, impartial, unanimous jury verdict,	1	1
State v. Lopezgreen arizctapp · 2008 · cited in 1 Arizona opinions naming this issue, 2015–2015 2 sentences 2015See Lopez, 217 Ariz. at 434-35, ¶ 4 , 175 P.3d at 683-84 (finding that an objection on one ground does not preserve the issue on another ground and, as a result, we only review for fundamental error). 2015See Lopez, 217 Ariz. at 434-35, ¶ 4 , 175 P.3d at 683-84 (finding that an objection on one ground does not preserve the issue on another ground and, as a result, we only review for fundamental error).	1	1
State v. Reynoldsgreen arizctapp · 1976 · cited in 1 Arizona opinions naming this issue, 1978–1978 2 sentences 1978We have held that a court is not required to advise a defendant of each specific ele 461 ment of an offense to which he is pleading guilty, absent the special circumstances of Henderson v. Morgan, supra. State v. Ohta, 114 Ariz. 489 , 562 P.2d 369 (1977); State v. Devine, 114 Ariz. 574 , 562 P.2d 1072 (1977); see also, State v. Reynolds, 25 Ariz.App. 409 , 544 P.2d 233 (1976). 1978We have held that a court is not required to advise a defendant of each specific ele 461 ment of an offense to which he is pleading guilty, absent the special circumstances of Henderson v. Morgan, supra. State v. Ohta, 114 Ariz. 489 , 562 P.2d 369 (1977); State v. Devine, 114 Ariz. 574 , 562 P.2d 1072 (1977); see also, State v. Reynolds, 25 Ariz.App. 409 , 544 P.2d 233 (1976).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (5)

Case	Cited	Years
State v. Hursey green ariz · 1993 2 sentences 2023Reading portions of Hursey into the record, the trial court noted that “[t]he mere fact of confidential communications in the prior relationship is enough to presume prejudice to the defendant.” Id. at 334 . 2023Accordingly, Henderson asserted that the court should presume prejudice to her and disqualify GCAO. ¶10 The State opposed the renewed motion, arguing that no good cause warranted reconsideration and that the Gomez factors did not support disqualification. ¶11 The trial court heard argument from the parties on Henderson’s motion and then recessed to review Hursey, which involved the disqualification of a prosecutor who had formally represented a defendant in a prior criminal matter. 176 Ariz. at 331 .	1	2023–2023
State of Arizona v. Hon. marner/darren Goldin green ariz · 2021 1 sentence 2023Cnty. of Pima, 251 Ariz. 198 (2021), and on new information not previously considered.	1	2023–2023
Henderson v. Morgan green scotus · 1976 2 sentences 1978Additionally, the Court found that Henderson’s plea was involuntary because nothing in the record indicated that he had the necessary intent. “ * * * [H]e made no factual statement or admission necessarily implying that he had such intent.” 426 U.S. 639 , 646, 96 S.Ct. 2253, 2258 , 49 L.Ed.2d 108, 115 . 1978Additionally, the Court found that Henderson’s plea was involuntary because nothing in the record indicated that he had the necessary intent. “ * * * [H]e made no factual statement or admission necessarily implying that he had such intent.” 426 U.S. 639 , 646, 96 S.Ct. 2253, 2258 , 49 L.Ed.2d 108, 115 .	1	1978–1978
State v. Devine green ariz · 1977 2 sentences 1978We have held that a court is not required to advise a defendant of each specific ele 461 ment of an offense to which he is pleading guilty, absent the special circumstances of Henderson v. Morgan, supra. State v. Ohta, 114 Ariz. 489 , 562 P.2d 369 (1977); State v. Devine, 114 Ariz. 574 , 562 P.2d 1072 (1977); see also, State v. Reynolds, 25 Ariz.App. 409 , 544 P.2d 233 (1976). 1978We have held that a court is not required to advise a defendant of each specific ele 461 ment of an offense to which he is pleading guilty, absent the special circumstances of Henderson v. Morgan, supra. State v. Ohta, 114 Ariz. 489 , 562 P.2d 369 (1977); State v. Devine, 114 Ariz. 574 , 562 P.2d 1072 (1977); see also, State v. Reynolds, 25 Ariz.App. 409 , 544 P.2d 233 (1976).	1	1978–1978
State v. Ohta green ariz · 1977 2 sentences 1978We have held that a court is not required to advise a defendant of each specific ele 461 ment of an offense to which he is pleading guilty, absent the special circumstances of Henderson v. Morgan, supra. State v. Ohta, 114 Ariz. 489 , 562 P.2d 369 (1977); State v. Devine, 114 Ariz. 574 , 562 P.2d 1072 (1977); see also, State v. Reynolds, 25 Ariz.App. 409 , 544 P.2d 233 (1976). 1978We have held that a court is not required to advise a defendant of each specific ele 461 ment of an offense to which he is pleading guilty, absent the special circumstances of Henderson v. Morgan, supra. State v. Ohta, 114 Ariz. 489 , 562 P.2d 369 (1977); State v. Devine, 114 Ariz. 574 , 562 P.2d 1072 (1977); see also, State v. Reynolds, 25 Ariz.App. 409 , 544 P.2d 233 (1976).	1	1978–1978

Where else courts name it

NJ 37 (2003–2025) CA 24 (1980–2026) TX 14 (2002–2025) PA 13 (2006–2022) OH 10 (1994–2026) IN 9 (1988–2018) IL 9 (2004–2018) AL 9 (1984–2025) GA 7 (1999–2023) MS 7 (1977–2017) WA 7 (1996–2026) TN 7 (1980–2016) VA 6 (1988–2025) AZ 6 (1978–2023) MA 5 (1982–2020) SC 3 (1988–2026) MD 3 (2009–2018) MO 3 (1992–2013) AR 3 (1995–2022) NE 3 (2014–2018) DC 3 (1985–2024) KS 3 (2019–2020) LA 3 (1987–2016) IA 2 (1994–2016) WV 2 (1986–1992) FL 2 (1996–2007) MI 2 (2003–2015)

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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