finding of harmless error (District of Columbia) · Go Syfert
← District of Columbia issues

finding of harmless error in District of Columbia

6 District of Columbia opinions name it 1 courts 1999–2020 0 in the last five years

The cases below were cited by District of Columbia 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 (8)

CaseFollowedCited
Bell v. United Statesgreen
dc · 2002 · cited in 5 District of Columbia opinions naming this issue, 2006–2020
2 sentences

2020“Mere sufficiency of the evidence . . . does not dictate a finding of harmless error.” Wilson-Bey, 903 A.2d at 844 (quoting Bell v. United States, 801 A.2d 117, 129 (D.C. 2002)).

2017In re Ty.B., 878 A.2d 1255, 1266-67 (D.C. 2005) (''[T]he sufficiency issue is distinct from that of harmless error.”); see also Bell v. United States, 801 A.2d 117, 129 (D.C. 2002) ("Mere sufficiency of the evidence ... does not dictate a finding of harmless error.”); Fox v. United States, 421 A.2d 9, 14 (D.C. 1980) (finding the evidence “sufficient to permit a guilty verdict ... [but] not, however, ... so strong as to justify a conclusion that the erro[r] ... was harmless”). .

55
Fox v. United Statesgreen
dc · 1980 · cited in 2 District of Columbia opinions naming this issue, 2017–2017
2 sentences

2017In re Ty.B., 878 A.2d 1255 , 1266–67 (D.C. 2005) (―[T]he sufficiency issue is distinct from that of harmless error.‖); see also Bell v. United States, 801 A.2d 117, 129 (D.C. 2002) (―Mere sufficiency of the evidence . . . does not dictate a finding of harmless error.‖); Fox v. United States, 421 A.2d 9, 14 (D.C. 1980) (finding the evidence ―sufficient to permit a guilty verdict . . . [but] not, however, . . . so strong as to justify a conclusion that the erro[r] . . . was harmless‖). 28 would have issued a guilty verdict in this case based on a determination that Mr. Carrell acted with purpose

2017In re Ty.B., 878 A.2d 1255, 1266-67 (D.C. 2005) (''[T]he sufficiency issue is distinct from that of harmless error.”); see also Bell v. United States, 801 A.2d 117, 129 (D.C. 2002) ("Mere sufficiency of the evidence ... does not dictate a finding of harmless error.”); Fox v. United States, 421 A.2d 9, 14 (D.C. 1980) (finding the evidence “sufficient to permit a guilty verdict ... [but] not, however, ... so strong as to justify a conclusion that the erro[r] ... was harmless”). .

22
Clark v. United Statesgreen
dc · 1991 · cited in 2 District of Columbia opinions naming this issue, 2006–2008
2 sentences

2008Even under the less rigorous standard of Kotteakos, [10] “analysis under the harmless error doctrine should not be limited to superficial inquiry as to whether the same verdict would have been possible absent the tainted evidence.” [Raymond] Brooks v. United States, 367 A.2d 1297, 1309 (D.C.1976); see also Clark v. United States, 593 A.2d 186, 192 (D.C.1991).

2006Even under the less rigorous standard of Kotteakos, “analysis under the harmless error doctrine should not be limited to superficial inquiry as to whether the same verdict would have been possible absent the tainted evidence.” 46 [Raymond] Brooks v. United States, 367 A.2d 1297, 1309 (D.C.1976); see also Clark v. United States, 593 A.2d 186, 192 (D.C.1991).

22
Brooks v. United Statesgreen
dc · 1976 · cited in 2 District of Columbia opinions naming this issue, 2006–2008
2 sentences

2008Even under the less rigorous standard of Kotteakos, [10] “analysis under the harmless error doctrine should not be limited to superficial inquiry as to whether the same verdict would have been possible absent the tainted evidence.” [Raymond] Brooks v. United States, 367 A.2d 1297, 1309 (D.C.1976); see also Clark v. United States, 593 A.2d 186, 192 (D.C.1991).

2006Even under the less rigorous standard of Kotteakos, “analysis under the harmless error doctrine should not be limited to superficial inquiry as to whether the same verdict would have been possible absent the tainted evidence.” 46 [Raymond] Brooks v. United States, 367 A.2d 1297, 1309 (D.C.1976); see also Clark v. United States, 593 A.2d 186, 192 (D.C.1991).

22
Wilson-Bey v. United Statesgreen
dc · 2006 · cited in 2 District of Columbia opinions naming this issue, 2008–2020
2 sentences

2020“Mere sufficiency of the evidence . . . does not dictate a finding of harmless error.” Wilson-Bey, 903 A.2d at 844 (quoting Bell v. United States, 801 A.2d 117, 129 (D.C. 2002)).

2008As the en banc court recently explained in Wilsan-Bey v. United States, 903 A.2d 818, 844 (D.C.2006) (en banc), cert. denied, — U.S. -, 127 S.Ct. 2248 , 167 L.Ed.2d 1089 (2007), “[m]ere sufficiency of the evidence does not dictate a finding of harmless error.” Bell v. United States, 801 A.2d 117, 129 (D.C.2002).

12
In Re Ty. B.green
dc · 2005 · cited in 2 District of Columbia opinions naming this issue, 2017–2017
2 sentences

2017In re Ty.B., 878 A.2d 1255 , 1266–67 (D.C. 2005) (―[T]he sufficiency issue is distinct from that of harmless error.‖); see also Bell v. United States, 801 A.2d 117, 129 (D.C. 2002) (―Mere sufficiency of the evidence . . . does not dictate a finding of harmless error.‖); Fox v. United States, 421 A.2d 9, 14 (D.C. 1980) (finding the evidence ―sufficient to permit a guilty verdict . . . [but] not, however, . . . so strong as to justify a conclusion that the erro[r] . . . was harmless‖). 28 would have issued a guilty verdict in this case based on a determination that Mr. Carrell acted with purpose

2017In re Ty.B., 878 A.2d 1255, 1266-67 (D.C. 2005) (''[T]he sufficiency issue is distinct from that of harmless error.”); see also Bell v. United States, 801 A.2d 117, 129 (D.C. 2002) ("Mere sufficiency of the evidence ... does not dictate a finding of harmless error.”); Fox v. United States, 421 A.2d 9, 14 (D.C. 1980) (finding the evidence “sufficient to permit a guilty verdict ... [but] not, however, ... so strong as to justify a conclusion that the erro[r] ... was harmless”). .

12
Leon Robinson and Shanika Robinson v. United Statesgreen
dc · 2014 · cited in 1 District of Columbia opinions naming this issue, 2020–2020
1 sentence

2020See generally Robinson, 100 A.3d at 108 . 6 Since the adoption of D.C.

11
United States v. Howard D. Browngreen
cadc · 1970 · cited in 1 District of Columbia opinions naming this issue, 1999–1999
2 sentences

1999In such cases, therefore, “the trial judge should address the defendant personally in determining whether the waiver is made voluntarily with understanding of the consequences of his act.” Brown, 138 U.S.App.D.C. at 401-402 , 428 F.2d at 1103-1104 (emphasis added). 8 Rule 11 specifically leaves room for a finding of harmless error.

1999In such cases, therefore, “the trial judge should address the defendant personally in determining whether the waiver is made voluntarily with understanding of the consequences of his act.” Brown, 138 U.S.App.D.C. at 401-402 , 428 F.2d at 1103-1104 (emphasis added). 8 Rule 11 specifically leaves room for a finding of harmless error.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Shirley Williams v. United States green
dc · 2014
1 sentence

2017We did not follow this "usual practice" in Williams (Shirley), however, because we determined that the evidence in the case was legally insufficient to support a finding of guilt. 90 A.3d at 1129 .

12017–2017
Wilson-Bey v. United States green
scotus · 2007
1 sentence

2008As the en banc court recently explained in Wilsan-Bey v. United States, 903 A.2d 818, 844 (D.C.2006) (en banc), cert. denied, — U.S. -, 127 S.Ct. 2248 , 167 L.Ed.2d 1089 (2007), “[m]ere sufficiency of the evidence does not dictate a finding of harmless error.” Bell v. United States, 801 A.2d 117, 129 (D.C.2002).

12008–2008

Statutes the citing opinions construe

DC § D.C. Code § 22-1810 (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

MI 26 (1975–2026) FL 25 (1984–2025) CA 22 (1967–2026) OH 19 (1997–2024) SC 15 (2008–2026) MD 13 (1976–2024) IL 12 (1972–2025) MS 11 (1993–2019) AL 10 (1985–2026) GA 9 (1978–2025) NY 8 (1976–2012) TX 8 (1982–2015) PA 8 (1986–2026) WA 7 (2007–2020) MA 6 (1973–2010) NJ 6 (1979–2020) DC 6 (1999–2020) NH 5 (1993–2023) TN 5 (1998–2024) IN 5 (1984–2002) LA 4 (2002–2025) ID 4 (2014–2022) MO 4 (1973–2010) CT 4 (1979–2018) VT 4 (2006–2009) WI 4 (1981–1991) IA 4 (2001–2015) AR 2 (1974–1982) NM 2 (1978–1996) AZ 2 (2007–2007)

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.

← Caselaw search · G Cite Topics · Brief Check