claim of plain error (Utah) · Go Syfert
← Utah issues

claim of plain error in Utah

51 Utah opinions name it 2 courts 1990–2026 11 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 (24)

CaseFollowedCited
State v. Dunngreen
utah · 1993 · cited in 13 Utah opinions naming this issue, 1993–2018
2 sentences

2018Finally, Defendant argues that his trial counsel was constitutionally ineffective. ¶ 19 Where Defendant's arguments rest on a claim of plain error, we require that he demonstrate: "(i) [a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome for the appellant, or phrased differently, our confidence in the verdict is undermined." State v. Dunn , 850 P.2d 1201 , 1208-09 (Utah 1993). ¶ 20 "The constitutionality of a statute is a question of law that we review

2017To succeed on a claim of plain error, a defendant must establish that “(i) [a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful.” State v. Dunn, 850 P.2d 1201, 1208 (Utah 1993). ¶69 Martinez-Castellanos contends that, “[w]hile the court should be commended for its part in recognizing and calling for post-trial proceedings to address ineffective assistance, it erred when it failed to appoint conflict counsel to represent [him] in a meaningful way.” Rather, “the court simply appointed an attorney as amicus to address one distinct issue for

1013
State v. Bullockgreen
utah · 1989 · cited in 8 Utah opinions naming this issue, 1990–2013
2 sentences

2013In other words, "if trial counsel's actions amounted to an active, as opposed to a passive, waiver of an objection, we may decline to consider the claim of plain error." Id. ¶ 23 As discussed in the preceding section, that is precisely what occurred here.

2012See State v. Hall, 946 P.2d 712, 716 (Utah Ct.App.1997) (stating that Utah appellate courts will decline to consider a claim of plain error if defense counsel made a "'conscious decision to refrain from objecting'" or " 'led the trial court into error " (quoting State v. Bullock, 791 P.2d 155, 158 (Utah 1989))).

68
State v. Holgategreen
utah · 2000 · cited in 3 Utah opinions naming this issue, 2001–2018
2 sentences

2018To succeed on a claim of plain error, a defendant "must establish harmful error that should have been obvious to the trial court." Id. (citing State v. Holgate , 2000 UT 74 , ¶ 13, 10 P.3d 346 ).

2018To succeed on a claim of plain error, a defendant "must establish harmful error that should have been obvious to the trial court." Id. (citing State v. Holgate , 2000 UT 74 , ¶ 13, 10 P.3d 346 ).

23
Strickland v. Washingtongreen
scotus · 1984 · cited in 3 Utah opinions naming this issue, 2012–2013
2 sentences

2013To establish ineffective assistance, a defendant must show that counsel's performance was deficient and prejudicial "to the degree that but for counsel's deficient performance, there is a reasonable probability that the outcome of the trial would have been different." Id. 19 (citation and internal quotation marks omitted); accord Strickland v. Washington, 466 U.S. 668, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) (explaining that "[a] reasonable probability is a probability sufficient to undermine confidence" in the verdict).

2013To establish ineffective assistance, a defendant must show that counsel's performance was deficient and prejudicial "to the degree that but for counsel's deficient performance, there is a reasonable probability that the outcome of the trial would have been different." Id. 19 (citation and internal quotation marks omitted); accord Strickland v. Washington, 466 U.S. 668, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) (explaining that "[a] reasonable probability is a probability sufficient to undermine confidence" in the verdict).

23
State v. Lowgreen
utah · 2008 · cited in 2 Utah opinions naming this issue, 2011–2013
2 sentences

2013See State v. Low, 2008 UT 58, ¶ 20 , 192 P.3d 867 (requiring the defendant to show an obvious error to support a claim of plain error).

2013See State v. Low, 2008 UT 58, ¶ 20 , 192 P.3d 867 (requiring the defendant to show an obvious error to support a claim of plain error).

22
State v. Snydergreen
utahctapp · 1993 · cited in 2 Utah opinions naming this issue, 2012–2012
2 sentences

2012Additionally, because the trial court ruled on this ineffectiveness argument in the rule 23B hearing, “the issues raised present mixed questions of law and fact.” State v. Snyder, 860 P.2d 351, 354 (Utah Ct. App. 1993) (citing Strickland v. Washington, 466 U.S. 668, 698 (1984)).

2012Additionally, because the trial court ruled on this ineffectiveness argument in the rule 28B hearing, "the issues raised present mixed questions of law and fact." State v. Snyder, 860 P.2d 351, 354 (Utah Ct.App.1993) (citing Strickland v. Washington, 466 U.S. 668, 698 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984)).

22
State v. Poppgreen
utahctapp · 2019 · cited in 2 Utah opinions naming this issue, 2024–2025
2 sentences

2024And to succeed on a claim of plain error, Mayorga “must establish that (i) an error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful.” State v. Popp, 2019 UT App 173, ¶ 35 , 453 P.3d 657 (quotation simplified).

2024And to succeed on a claim of plain error, Mayorga “must establish that (i) an error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful.” State v. Popp, 2019 UT App 173, ¶ 35 , 453 P.3d 657 (quotation simplified).

12
State v. Bondgreen
utah · 2015 · cited in 2 Utah opinions naming this issue, 2017–2021
2 sentences

2021“To prevail on a claim of plain error,” a defendant must show that “(i) an error exists; (ii) the error should have been obvious to the [district] court; and (iii) the error is harmful.” State v. Bedell, 2014 UT 1, ¶ 20 , 322 P.3d 697 (cleaned up). ¶17 The merger doctrine, as codified in Utah’s merger statute, is designed “to protect criminal defendants from being twice punished for committing a single act that may violate more than one criminal statute.” State v. Bond, 2015 UT 88, ¶ 65 , 361 P.3d 104 (cleaned up); see also Utah Code Ann. § 76-1 - 402(1) (LexisNexis 2017).

2021“To prevail on a claim of plain error,” a defendant must show that “(i) an error exists; (ii) the error should have been obvious to the [district] court; and (iii) the error is harmful.” State v. Bedell, 2014 UT 1, ¶ 20 , 322 P.3d 697 (cleaned up). ¶17 The merger doctrine, as codified in Utah’s merger statute, is designed “to protect criminal defendants from being twice punished for committing a single act that may violate more than one criminal statute.” State v. Bond, 2015 UT 88, ¶ 65 , 361 P.3d 104 (cleaned up); see also Utah Code Ann. § 76-1 - 402(1) (LexisNexis 2017).

12
State v. Rossgreen
utahctapp · 1997 · cited in 2 Utah opinions naming this issue, 2002–2004
2 sentences

2004See State v. Eldredge, 773 P.2d 29, 35-36 (Utah 1989) (rejecting a claim of plain error where a dispositive appellate case had not yet been decided); see also State v. Ross, 951 P.2d 236, 239 (Utah Ct.App.1997) (stating “error is not plain where there is no settled appellate law to guide the trial court”). ¶ 17 In this context and on these facts, we find that any error committed by the trial court was not obvious at the time the court denied Dean’s motion to withdraw.

2002"Utah courts have repeatedly held that a trial court's error is not plain where there is no settled appellate law to guide the trial court." Id. at 239 ; see also State v. Braun, 787 P.2d 1336, 1341-42 (Utah Ct.App.1990) (rejecting a claim of plain error where "`the trial court did not have the benefit of [a later] appellate decision'" (citation omitted) (alteration in original)).

12
State v. Eldredgegreen
utah · 1989 · cited in 2 Utah opinions naming this issue, 1994–2004
2 sentences

2004See State v. Eldredge, 773 P.2d 29, 35-36 (Utah 1989) (rejecting a claim of plain error where a dispositive appellate case had not yet been decided); see also State v. Ross, 951 P.2d 236, 239 (Utah Ct.App.1997) (stating “error is not plain where there is no settled appellate law to guide the trial court”). ¶ 17 In this context and on these facts, we find that any error committed by the trial court was not obvious at the time the court denied Dean’s motion to withdraw.

1994Eldredge, 773 P.2d at 36 n. 12.

12
Parker v. Duggergreen
scotus · 1990 · cited in 2 Utah opinions naming this issue, 1991–1997
2 sentences

1991“For example, if trial counsel’s actions amounted to an active, as opposed to a passive, waiver of an objection, we may decline to consider the claim of plain error.” State v. Bullock, 791 P.2d 155, 158 (Utah 1989) (citations omitted) (supreme court does not reach the issue of plain error in child sexual abuse case, concluding counsel failed to object as part of trial strategy), cert. denied by Bullock v. Utah, — U.S. —, 110 S.Ct. 3270 , 111 L.Ed.2d 780 (1990).

1991"For example, if trial counsel's actions amounted to an active, as opposed to a passive, waiver of an objection, we may decline to consider the claim of plain error." State v. Bullock, 791 P.2d 155, 158 (Utah 1989) (citations omitted) (supreme court does not reach the issue of plain error in child sexual abuse case, concluding counsel failed to object as part of trial strategy), cert. denied by Bullock v. Utah, ___ U.S. ___, 110 S.Ct. 3270 , 111 L.Ed.2d 780 (1990).

12
State v. Corrygreen
utahctapp · 2024 · cited in 1 Utah opinions naming this issue, 2025–2025
2 sentences

2025See State v. Corry, 2024 UT App 142, ¶ 17 , 558 P.3d 128 .

2025See State v. Corry, 2024 UT App 142, ¶ 17 , 558 P.3d 128 .

11
State v. Henflinggreen
utahctapp · 2020 · cited in 1 Utah opinions naming this issue, 2022–2022
11
State v. McNeilgreen
utah · 2016 · cited in 1 Utah opinions naming this issue, 2022–2022
11
State v. Alfatlawigreen
utahctapp · 2006 · cited in 1 Utah opinions naming this issue, 2017–2017
11
State v. Hallgreen
utahctapp · 1997 · cited in 1 Utah opinions naming this issue, 2012–2012
11
State v. Verdegreen
utah · 1989 · cited in 1 Utah opinions naming this issue, 2011–2011
11
State v. Maasgreen
utahctapp · 1999 · cited in 1 Utah opinions naming this issue, 2011–2011
11
State v. Braungreen
utahctapp · 1990 · cited in 1 Utah opinions naming this issue, 2002–2002
11
State v. Garciagreen
utahctapp · 2001 · cited in 1 Utah opinions naming this issue, 2002–2002
11
State v. Marvingreen
utah · 1998 · cited in 1 Utah opinions naming this issue, 2000–2000
11
State v. Gibbonsgreen
utah · 1987 · cited in 1 Utah opinions naming this issue, 2000–2000
11
Endsley v. Younggreen
scotus · 1990 · cited in 1 Utah opinions naming this issue, 1997–1997
11
State v. Butterfieldgreen
utah · 1989 · cited in 1 Utah opinions naming this issue, 1991–1991
11

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 (32)

CaseCitedYears
State v. Boyd green
utah · 2001
2 sentences

2013To prevail on a claim of plain error, Patterson must show that an error occurred at trial; "that the error should have been obvious to the trial court[;] and that the error is harmful, ie., absent the error, there is a reasonable likelihood of a more favorable outcome for the appellant, or phrased differently, our confidence in the verdict is undermined." State v. Boyd, 2001 UT 30, ¶ 21 , 25 P.3d 985 (citation and internal quotation marks omitted).

2013To prevail on a claim of plain error, Patterson must show that an error occurred at trial; "that the error should have been obvious to the trial court[;] and that the error is harmful, ie., absent the error, there is a reasonable likelihood of a more favorable outcome for the appellant, or phrased differently, our confidence in the verdict is undermined." State v. Boyd, 2001 UT 30, ¶ 21 , 25 P.3d 985 (citation and internal quotation marks omitted).

32012–2013
State v. Tarnawiecki green
utahctapp · 2000
2 sentences

2002See State v. Garcia, 2001 UT App 19, ¶ 6 , 18 P.3d 1123 . " 'To succeed on a claim of plain error, a defendant has the burden of showing (N[aln error exists; () the error should have been obvious to the trial court; and (iii) the error is harmful.'" State v. Tarnawiecki, 2000 UT App 186, ¶ 11 , 5 P.3d 1222 (citations and internal quotations omitted) (alteration in original).

2002See State v. Garcia, 2001 UT App 19, ¶ 6 , 18 P.3d 1123 . " 'To succeed on a claim of plain error, a defendant has the burden of showing (N[aln error exists; () the error should have been obvious to the trial court; and (iii) the error is harmful.'" State v. Tarnawiecki, 2000 UT App 186, ¶ 11 , 5 P.3d 1222 (citations and internal quotations omitted) (alteration in original).

32002–2004
State v. Dew green
utahctapp · 2025
2 sentences

2026“Because a claim of plain error . . . involves no lower court ruling, we decide the claim in the first instance as a matter of law.” State v. Dew, 2025 UT App 22, ¶ 28 , 566 P.3d 53 , cert. denied, 568 P.3d 264 (Utah 2025). 20230210-CA 9 2026 UT App 53 State v. Taylor ANALYSIS ¶14 Taylor makes two assertions of plain error, one based on Mother’s testimony regarding his character and one based on the special verdict form.

2026“Because a claim of plain error . . . involves no lower court ruling, we decide the claim in the first instance as a matter of law.” State v. Dew, 2025 UT App 22, ¶ 28 , 566 P.3d 53 , cert. denied, 568 P.3d 264 (Utah 2025). 20230210-CA 9 2026 UT App 53 State v. Taylor ANALYSIS ¶14 Taylor makes two assertions of plain error, one based on Mother’s testimony regarding his character and one based on the special verdict form.

22025–2026
In re S.T... green
utahctapp · 2022
2 sentences

2023Therefore, “we (continued…) 20220635-CA 10 2023 UT App 144 In re R.G. succeed on a claim of plain error, Father must show that “(1) an error exists; (2) the error should have been obvious to the juvenile court; and (3) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome.” In re S.T., 2022 UT App 130, ¶ 14 , 521 P.3d 887 (quotation simplified).

2022To succeed on a claim of plain error, Mother must show that “(1) an error exists; (2) the error should have been obvious to the [juvenile] court; and (3) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome.” See In re J.A.L., 2022 UT 12, ¶ 12 , 506 P.3d 606 (quotation simplified). 20220029-CA 6 2022 UT App 130 In re S.T. ¶15 Second, Mother argues the juvenile court abused its discretion in determining that terminating her parental rights was in the best interest of the Children.

22022–2023
State v. Bedell green
utah · 2014
2 sentences

2021“To prevail on a claim of plain error,” a defendant must show that “(i) an error exists; (ii) the error should have been obvious to the [district] court; and (iii) the error is harmful.” State v. Bedell, 2014 UT 1, ¶ 20 , 322 P.3d 697 (cleaned up). ¶17 The merger doctrine, as codified in Utah’s merger statute, is designed “to protect criminal defendants from being twice punished for committing a single act that may violate more than one criminal statute.” State v. Bond, 2015 UT 88, ¶ 65 , 361 P.3d 104 (cleaned up); see also Utah Code Ann. § 76-1 - 402(1) (LexisNexis 2017).

2021“To prevail on a claim of plain error,” a defendant must show that “(i) an error exists; (ii) the error should have been obvious to the [district] court; and (iii) the error is harmful.” State v. Bedell, 2014 UT 1, ¶ 20 , 322 P.3d 697 (cleaned up). ¶17 The merger doctrine, as codified in Utah’s merger statute, is designed “to protect criminal defendants from being twice punished for committing a single act that may violate more than one criminal statute.” State v. Bond, 2015 UT 88, ¶ 65 , 361 P.3d 104 (cleaned up); see also Utah Code Ann. § 76-1 - 402(1) (LexisNexis 2017).

22018–2021
State v. Reigelsperger green
utahctapp · 2017
2 sentences

2018Especially considering the district court's conclusions that the attorney who represented Newton at trial was not constitutionally ineffective on any claim Newton raised and the court did not find credible the testimony of Newton's father. 5 A surveillance video of the fast food restaurant showed that Newton and Victim entered the restaurant around 3:00 a.m., that Victim was seen using her cell phone, and that Victim and Newton left together at around 3:09 a.m. 6 To the extent Newton argues that we should review this issue under the rubrics of plain error and manifest injustice, those argument

2018Especially considering the district court's conclusions that the attorney who represented Newton at trial was not constitutionally ineffective on any claim Newton raised and the court did not find credible the testimony of Newton's father. 5 A surveillance video of the fast food restaurant showed that Newton and Victim entered the restaurant around 3:00 a.m., that Victim was seen using her cell phone, and that Victim and Newton left together at around 3:09 a.m. 6 To the extent Newton argues that we should review this issue under the rubrics of plain error and manifest injustice, those argument

22018–2018
State v. Dean green
utah · 2004
2 sentences

2017See State v. Bond, 2015 UT 88, ¶ 63 , 361 P.3d 104 (rejecting a claim of ineffective assistance of counsel, concluding that if trial counsel had made the motion at issue, it would have been futile); State v. Dean, 2004 UT 63, ¶ 21 , 95 P.3d 276 (rejecting a claim of plain error because “the law in this area was not plainly settled so as to have adequately guided the trial court” at the time the alleged error occurred).

2017See State v. Bond, 2015 UT 88, ¶ 63 , 361 P.3d 104 (rejecting a claim of ineffective assistance of counsel, concluding that if trial counsel had made the motion at issue, it would have been futile); State v. Dean, 2004 UT 63, ¶ 21 , 95 P.3d 276 (rejecting a claim of plain error because “the law in this area was not plainly settled so as to have adequately guided the trial court” at the time the alleged error occurred).

22017–2018
State v. Hare neutral
utahctapp · 2015
2 sentences

2017Thus, we conclude that her specific arguments regarding the court’s alimony determinations have not been preserved for appeal, see id., and we review them for plain error. ¶ 39 “To prevail on a claim of plain error, the appellant must show obvious, prejudicial error.” State v. Hare, 2015 UT App 179, ¶ 9 , 355 P.3d 1071 , We conclude that the court’s equalization analysis constituted plain error and remand for further proceedings.

2017Thus, we conclude that her specific arguments regarding the court’s alimony determinations have not been preserved for appeal, see id., and we review them for plain error. ¶ 39 “To prevail on a claim of plain error, the appellant must show obvious, prejudicial error.” State v. Hare, 2015 UT App 179, ¶ 9 , 355 P.3d 1071 , We conclude that the court’s equalization analysis constituted plain error and remand for further proceedings.

22016–2017
State v. Hittle green
utahctapp · 2002
2 sentences

2002To succeed on a claim of plain error, a defendant has the burden of showing (i)[a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful.” Id. (quotations and citations omitted).

2002To succeed on a claim of plain error, a defendant has the burden of showing (i)[a]n error exists; (ii) the error should have been obvious to the trial court; and (iii) the error is harmful." Id. (quotations and citations omitted).

22002–2004
State v. Skinner green
utahctapp · 2020
1 sentence

2026Where, as here, the alleged error is the failure to sua sponte disregard witness testimony as inherently improbable, to prevail on a claim of plain error, the defendant must show that the testimony “was so obviously and fundamentally faulty that the trial court should have stepped in and excluded that testimony from the equation without specifically being asked to do so.” Id. ¶26 The proper test to determine whether testimony is “inherently improbable” is “whether the testimony could support a conviction or whether reasonable minds must have entertained a reasonable doubt that the defendant co

12026–2026
State v. Johnson green
utahctapp · 2023
2 sentences

2026“Under the plain error standard of review, a defendant must demonstrate that (i) an error exists; (ii) the error should have been obvious to the [trial] court; and (iii) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome for the appellant.” State v. Johnson, 2023 UT App 145, ¶ 22 , 540 P.3d 744 (quotation simplified).

2026“Under the plain error standard of review, a defendant must demonstrate that (i) an error exists; (ii) the error should have been obvious to the [trial] court; and (iii) the error is harmful, i.e., absent the error, there is a reasonable likelihood of a more favorable outcome for the appellant.” State v. Johnson, 2023 UT App 145, ¶ 22 , 540 P.3d 744 (quotation simplified).

12026–2026
State v. Jok green
utah · 2021
2 sentences

2026Where, as here, the alleged error is the failure to sua sponte disregard witness testimony as inherently improbable, to prevail on a claim of plain error, the defendant must show that the testimony “was so obviously and fundamentally faulty that the trial court should have stepped in and excluded that testimony from the equation without specifically being asked to do so.” Id. ¶26 The proper test to determine whether testimony is “inherently improbable” is “whether the testimony could support a conviction or whether reasonable minds must have entertained a reasonable doubt that the defendant co

2026Where, as here, the alleged error is the failure to sua sponte disregard witness testimony as inherently improbable, to prevail on a claim of plain error, the defendant must show that the testimony “was so obviously and fundamentally faulty that the trial court should have stepped in and excluded that testimony from the equation without specifically being asked to do so.” Id. ¶26 The proper test to determine whether testimony is “inherently improbable” is “whether the testimony could support a conviction or whether reasonable minds must have entertained a reasonable doubt that the defendant co

12026–2026
cluster 10840911 green
·
1 sentence

2026“Because a claim of plain error . . . involves no lower court ruling, we decide the claim in the first instance as a matter of law.” State v. Dew, 2025 UT App 22, ¶ 28 , 566 P.3d 53 , cert. denied, 568 P.3d 264 (Utah 2025). 20230210-CA 9 2026 UT App 53 State v. Taylor ANALYSIS ¶14 Taylor makes two assertions of plain error, one based on Mother’s testimony regarding his character and one based on the special verdict form.

12026–2026
State v. Samora green
utahctapp · 2022
2 sentences

2025State v. Samora, 2022 UT App 7, ¶ 16 , 504 P.3d 195 ; accord State v. Popp, 2019 UT App 173, ¶ 19 , 453 P.3d 657 . ¶6 Jakeman next asserts that Subsection (5) is unconstitutional as applied to his case because the CPOs “resulted in the de facto termination of [his] parental rights without due process.” Because this issue was not preserved, we again review it under the plain error doctrine.

2025State v. Samora, 2022 UT App 7, ¶ 16 , 504 P.3d 195 ; accord State v. Popp, 2019 UT App 173, ¶ 19 , 453 P.3d 657 . ¶6 Jakeman next asserts that Subsection (5) is unconstitutional as applied to his case because the CPOs “resulted in the de facto termination of [his] parental rights without due process.” Because this issue was not preserved, we again review it under the plain error doctrine.

12025–2025
State v. Norton green
utah · 2020
1 sentence

2024“The prejudice analysis is the same for claims of plain error and ineffective assistance of counsel.” State v. Norton, 2021 UT 2 , ¶ 101, 481 P.3d 445 .

12024–2024
State v. Rammel green
utah · 1986
1 sentence

2024Failure to meet any of these requirements is fatal to a claim of plain error.” State v. Winter, 2024 UT App 98, ¶ 17 , 554 P.3d 355 (cleaned up), cert. denied, Oct. 10, 2024 (No. 20240977). ¶20 Garcia-Cardiel claims that State Expert’s statement about “some research that suggests that 60 to 80 percent of all abuse is not [reported] at all or . . . not reported until adulthood” resembles the inadmissible probability evidence in State v. Rammel, 721 P.2d 498 (Utah 1986), and State v. Iorg, 801 P.2d 938 (Utah Ct. App. 1990).

12024–2024
State v. Winter green
utahctapp · 2024
2 sentences

2024Failure to meet any of these requirements is fatal to a claim of plain error.” State v. Winter, 2024 UT App 98, ¶ 17 , 554 P.3d 355 (cleaned up), cert. denied, Oct. 10, 2024 (No. 20240977). ¶20 Garcia-Cardiel claims that State Expert’s statement about “some research that suggests that 60 to 80 percent of all abuse is not [reported] at all or . . . not reported until adulthood” resembles the inadmissible probability evidence in State v. Rammel, 721 P.2d 498 (Utah 1986), and State v. Iorg, 801 P.2d 938 (Utah Ct. App. 1990).

2024Failure to meet any of these requirements is fatal to a claim of plain error.” State v. Winter, 2024 UT App 98, ¶ 17 , 554 P.3d 355 (cleaned up), cert. denied, Oct. 10, 2024 (No. 20240977). ¶20 Garcia-Cardiel claims that State Expert’s statement about “some research that suggests that 60 to 80 percent of all abuse is not [reported] at all or . . . not reported until adulthood” resembles the inadmissible probability evidence in State v. Rammel, 721 P.2d 498 (Utah 1986), and State v. Iorg, 801 P.2d 938 (Utah Ct. App. 1990).

12024–2024
State v. Iorg green
utahctapp · 1990
1 sentence

2024Failure to meet any of these requirements is fatal to a claim of plain error.” State v. Winter, 2024 UT App 98, ¶ 17 , 554 P.3d 355 (cleaned up), cert. denied, Oct. 10, 2024 (No. 20240977). ¶20 Garcia-Cardiel claims that State Expert’s statement about “some research that suggests that 60 to 80 percent of all abuse is not [reported] at all or . . . not reported until adulthood” resembles the inadmissible probability evidence in State v. Rammel, 721 P.2d 498 (Utah 1986), and State v. Iorg, 801 P.2d 938 (Utah Ct. App. 1990).

12024–2024
In re R.G. neutral
utahctapp · 2023
12023–2023
In re J.L... green
utah · 2022
12022–2022
State v. Corona green
utahctapp · 2018
12021–2021
State v. Valdovinos green
utahctapp · 2003
12018–2018
State v. Heywood green
utahctapp · 2015
12018–2018
State v. Angilau green
utah · 2011
12018–2018
Salt Lake City v. Carrera green
utah · 2015
12018–2018
Dickman Family Properties, Inc. v. White green
utahctapp · 2013
12017–2017
State v. Harris green
utah · 2012
12014–2014
State v. King green
utah · 2006
12014–2014
State v. Sellers green
utahctapp · 2011
12013–2013
State v. Ross red
utah · 2007
12011–2011
State v. Cruz green
utah · 2005
12007–2007
State v. Ostler green
utahctapp · 2000
12000–2000

Statutes the citing opinions construe

UT § Utah Code § 76-5-404.1 (7) UT § Utah Code § 76-5-301 (4) UT § Utah Code § 76-5-403.1 (3) UT § Utah Code § 77-13-6 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 351 (1999–2026) MO 188 (1983–2025) UT 51 (1990–2026) IL 30 (2010–2026) CT 23 (1988–2026) GA 15 (2015–2026) WY 9 (1977–2020) OR 9 (2004–2026) AK 8 (1974–2021) NJ 7 (1962–2021) CO 6 (1986–2012) AL 6 (2000–2017) NM 5 (1986–2023) VT 4 (2010–2023) DC 4 (1981–2015) TN 3 (1999–2025) OK 2 (2016–2016) DE 2 (2001–2025)

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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