sua sponte waiver (Arizona) · Go Syfert
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sua sponte waiver in Arizona

6 Arizona opinions name it 2 courts 1980–2023 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 (4)

CaseFollowedCited
State v. Gulbrandsongreen
ariz · 1995 · cited in 1 Arizona opinions naming this issue, 2023–2023
1 sentence

2023Additionally, "a defendant must make his desire to testify known at trial and cannot allege this desire as an afterthought," and a trial court need not conduct "a sua sponte inquiry . . . regarding a defendant's right to testify." State v. Gulbrandson, 184 Ariz. 46, 65 (1995).

11
State v. Fogelgreen
arizctapp · 1972 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013Cf. State v. Pena, 209 Ariz. 503, ¶ 15 , 104 P.3d 873, 877 (App.2005) (error harmless if “absent the error, the court would have reached the same result”). ¶ 7 Banda next argues that, because the period prescribed by a statute of limitations is jurisdictional in Arizona, he is permitted to raise it pursuant to Rule 32.1(b), which permits relief if “[t]he court was without jurisdiction to render judgment or to impose sentence.” He contends the trial court improperly “disagree[d]” with our decision in Taylor v. Cruikshank, 214 Ariz. 40 , 148 P.3d 84 (App.2006), by determining “that a statute of

2013Cf. State v. Pena, 209 Ariz. 503, ¶ 15 , 104 P.3d 873, 877 (App.2005) (error harmless if “absent the error, the court would have reached the same result”). ¶ 7 Banda next argues that, because the period prescribed by a statute of limitations is jurisdictional in Arizona, he is permitted to raise it pursuant to Rule 32.1(b), which permits relief if “[t]he court was without jurisdiction to render judgment or to impose sentence.” He contends the trial court improperly “disagree[d]” with our decision in Taylor v. Cruikshank, 214 Ariz. 40 , 148 P.3d 84 (App.2006), by determining “that a statute of

11
State v. Penagreen
arizctapp · 2005 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013Cf. State v. Pena, 209 Ariz. 503, ¶ 15 , 104 P.3d 873, 877 (App.2005) (error harmless if “absent the error, the court would have reached the same result”). ¶ 7 Banda next argues that, because the period prescribed by a statute of limitations is jurisdictional in Arizona, he is permitted to raise it pursuant to Rule 32.1(b), which permits relief if “[t]he court was without jurisdiction to render judgment or to impose sentence.” He contends the trial court improperly “disagree[d]” with our decision in Taylor v. Cruikshank, 214 Ariz. 40 , 148 P.3d 84 (App.2006), by determining “that a statute of

2013Cf. State v. Pena, 209 Ariz. 503, ¶ 15 , 104 P.3d 873, 877 (App.2005) (error harmless if “absent the error, the court would have reached the same result”). ¶ 7 Banda next argues that, because the period prescribed by a statute of limitations is jurisdictional in Arizona, he is permitted to raise it pursuant to Rule 32.1(b), which permits relief if “[t]he court was without jurisdiction to render judgment or to impose sentence.” He contends the trial court improperly “disagree[d]” with our decision in Taylor v. Cruikshank, 214 Ariz. 40 , 148 P.3d 84 (App.2006), by determining “that a statute of

11
Rueda v. Galvezgreen
ariz · 1963 · cited in 1 Arizona opinions naming this issue, 1980–1980
2 sentences

1980See Rueda v. Galvez, 94 Ariz. 131 , 382 P.2d 239 (1963).

1980See Rueda v. Galvez, 94 Ariz. 131 , 382 P.2d 239 (1963).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Beck v. Alabama green
scotus · 1980
2 sentences

1988Although in capital cases, a defendant has a constitutional right pursuant to the due process clause to a sua sponte instruction on all lesser-included counts of first degree murder, Beck v. Alabama, 447 U.S. 625 , 100 S.Ct. 2382 , 65 L.Ed.2d 392 (1980), this holding has not been extended to noncapital offenses.

1988Although in capital cases, a defendant has a constitutional right pursuant to the due process clause to a sua sponte instruction on all lesser-included counts of first degree murder, Beck v. Alabama, 447 U.S. 625 , 100 S.Ct. 2382 , 65 L.Ed.2d 392 (1980), this holding has not been extended to noncapital offenses.

21985–1988
Taylor v. Cruikshank green
arizctapp · 2006
2 sentences

2013Cf. State v. Pena, 209 Ariz. 503, ¶ 15 , 104 P.3d 873, 877 (App.2005) (error harmless if “absent the error, the court would have reached the same result”). ¶ 7 Banda next argues that, because the period prescribed by a statute of limitations is jurisdictional in Arizona, he is permitted to raise it pursuant to Rule 32.1(b), which permits relief if “[t]he court was without jurisdiction to render judgment or to impose sentence.” He contends the trial court improperly “disagree[d]” with our decision in Taylor v. Cruikshank, 214 Ariz. 40 , 148 P.3d 84 (App.2006), by determining “that a statute of

2013Cf. State v. Pena, 209 Ariz. 503, ¶ 15 , 104 P.3d 873, 877 (App.2005) (error harmless if “absent the error, the court would have reached the same result”). ¶ 7 Banda next argues that, because the period prescribed by a statute of limitations is jurisdictional in Arizona, he is permitted to raise it pursuant to Rule 32.1(b), which permits relief if “[t]he court was without jurisdiction to render judgment or to impose sentence.” He contends the trial court improperly “disagree[d]” with our decision in Taylor v. Cruikshank, 214 Ariz. 40 , 148 P.3d 84 (App.2006), by determining “that a statute of

12013–2013
State v. Allie green
ariz · 1985
1 sentence

1995In Allie , the court held that a sua sponte inquiry by the trial court regarding a defendant’s right to testify is neither necessary nor appropriate. 147 Ariz. at 328, 710 P.2d at 438 .

11995–1995
Haco Drilling Company v. Hammer green
okla · 1967
1 sentence

1995Although we think that in an appropriate case it may be prudent for a trial court to have a defendant make an on-the-record waiver of the right to testify, see Martin, 102 Ariz. at 145 , 426 P.2d at 642 , it is not generally required under Arizona law.

11995–1995
State v. Martin green
ariz · 1967
1 sentence

1995Although we think that in an appropriate case it may be prudent for a trial court to have a defendant make an on-the-record waiver of the right to testify, see Martin, 102 Ariz. at 145 , 426 P.2d at 642 , it is not generally required under Arizona law.

11995–1995

Where else courts name it

CA 170 (1968–2026) NY 88 (1988–2026) TX 21 (1992–2025) MO 21 (1973–2024) DC 12 (1972–2017) MI 12 (1976–2025) MA 11 (1980–2023) OH 10 (1991–2016) MS 10 (2001–2007) GA 7 (2007–2026) KS 7 (2000–2024) NJ 6 (2006–2020) CO 6 (1996–2025) OK 6 (2002–2024) IN 6 (2002–2023) AZ 6 (1980–2023) PA 5 (1979–2025) NC 4 (1976–2021) IL 4 (1995–2026) RI 4 (2010–2013) HI 3 (2000–2011) TN 3 (2000–2015) NV 2 (1986–2020) ID 2 (2012–2024) WV 2 (1991–2025) AL 2 (2000–2016) OR 2 (1999–2025) WA 2 (2008–2008) CT 2 (1999–2017)

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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