Pena standard (Delaware) · Go Syfert
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Pena standard in Delaware

5 Delaware opinions name it 2 courts 2008–2021 1 in the last five years

The cases below were cited by Delaware 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
Pena v. Stategreen
del · 2004 · cited in 3 Delaware opinions naming this issue, 2015–2021
2 sentences

2021In Pena, this Court set forth a 75 Id. 76 Id. at A403-04. 77 Id. at A1276. 78 Id. at A1458 (Jury Instructions). 79 856 A.2d 548, 550-51 (Del. 2004) (citing Griffith v. State, 2003 WL 1987915 , at *4 (Del. 2003)). 80 Opening Br. at 25 n.10. 81 Chambers v. State, 930 A.2d 904, 909 (Del. 2007). 19 four-factor test for appellate review of an alleged prejudicial remark by a witness: (1) the nature and frequency of the offending comment; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the adequacy of the judge’s actions to mitigate any potential prejudice.82 Here, i

2021In Pena, this Court set forth a 75 Id. 76 Id. at A403-04. 77 Id. at A1276. 78 Id. at A1458 (Jury Instructions). 79 856 A.2d 548, 550-51 (Del. 2004) (citing Griffith v. State, 2003 WL 1987915 , at *4 (Del. 2003)). 80 Opening Br. at 25 n.10. 81 Chambers v. State, 930 A.2d 904, 909 (Del. 2007). 19 four-factor test for appellate review of an alleged prejudicial remark by a witness: (1) the nature and frequency of the offending comment; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the adequacy of the judge’s actions to mitigate any potential prejudice.82 Here, i

13
Chambers v. Stategreen
del · 2007 · cited in 1 Delaware opinions naming this issue, 2021–2021
2 sentences

2021In Pena, this Court set forth a 75 Id. 76 Id. at A403-04. 77 Id. at A1276. 78 Id. at A1458 (Jury Instructions). 79 856 A.2d 548, 550-51 (Del. 2004) (citing Griffith v. State, 2003 WL 1987915 , at *4 (Del. 2003)). 80 Opening Br. at 25 n.10. 81 Chambers v. State, 930 A.2d 904, 909 (Del. 2007). 19 four-factor test for appellate review of an alleged prejudicial remark by a witness: (1) the nature and frequency of the offending comment; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the adequacy of the judge’s actions to mitigate any potential prejudice.82 Here, i

2021In Pena, this Court set forth a 75 Id. 76 Id. at A403-04. 77 Id. at A1276. 78 Id. at A1458 (Jury Instructions). 79 856 A.2d 548, 550-51 (Del. 2004) (citing Griffith v. State, 2003 WL 1987915 , at *4 (Del. 2003)). 80 Opening Br. at 25 n.10. 81 Chambers v. State, 930 A.2d 904, 909 (Del. 2007). 19 four-factor test for appellate review of an alleged prejudicial remark by a witness: (1) the nature and frequency of the offending comment; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the adequacy of the judge’s actions to mitigate any potential prejudice.82 Here, i

11
Bailey v. Stategreen
del · 1987 · cited in 1 Delaware opinions naming this issue, 2020–2020
2 sentences

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

11
United States v. Lawrence Simon Postongreen
ca6 · 1970 · cited in 1 Delaware opinions naming this issue, 2020–2020
2 sentences

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

11
Dawson v. Stategreen
del · 1994 · cited in 1 Delaware opinions naming this issue, 2020–2020
2 sentences

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

11
Smith v. Stategreen
del · 2008 · cited in 1 Delaware opinions naming this issue, 2015–2015
2 sentences

2015The remedy of a mistrial is mandated only when there are no meaningfiil and practical alternatives to that remedy.”3 1 Smith v. State, 963 A.2d 719, 722 (Del. 2008). 2 Revel v. State, 956 A.2d 23, 27 (Del. 2008). 3 Smith, 963 A.2d at 722 (internal quotations omitted). 5 (13) In Pena v. State, this Court developed a four—part analysis to determine whether the unsolicited comments of a witness require the trial judge to declare a mistrial.4 This analysis considers: (1) the nature and frequency of the comments; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the s

2015The remedy of a mistrial is mandated only when there are no meaningfiil and practical alternatives to that remedy.”3 1 Smith v. State, 963 A.2d 719, 722 (Del. 2008). 2 Revel v. State, 956 A.2d 23, 27 (Del. 2008). 3 Smith, 963 A.2d at 722 (internal quotations omitted). 5 (13) In Pena v. State, this Court developed a four—part analysis to determine whether the unsolicited comments of a witness require the trial judge to declare a mistrial.4 This analysis considers: (1) the nature and frequency of the comments; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the s

11
Revel v. Stategreen
del · 2008 · cited in 1 Delaware opinions naming this issue, 2015–2015
2 sentences

2015The remedy of a mistrial is mandated only when there are no meaningfiil and practical alternatives to that remedy.”3 1 Smith v. State, 963 A.2d 719, 722 (Del. 2008). 2 Revel v. State, 956 A.2d 23, 27 (Del. 2008). 3 Smith, 963 A.2d at 722 (internal quotations omitted). 5 (13) In Pena v. State, this Court developed a four—part analysis to determine whether the unsolicited comments of a witness require the trial judge to declare a mistrial.4 This analysis considers: (1) the nature and frequency of the comments; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the s

2015The remedy of a mistrial is mandated only when there are no meaningfiil and practical alternatives to that remedy.”3 1 Smith v. State, 963 A.2d 719, 722 (Del. 2008). 2 Revel v. State, 956 A.2d 23, 27 (Del. 2008). 3 Smith, 963 A.2d at 722 (internal quotations omitted). 5 (13) In Pena v. State, this Court developed a four—part analysis to determine whether the unsolicited comments of a witness require the trial judge to declare a mistrial.4 This analysis considers: (1) the nature and frequency of the comments; (2) the likelihood of resulting prejudice; (3) the closeness of the case; and (4) the s

11
Justice v. Stategreen
del · 2008 · cited in 1 Delaware opinions naming this issue, 2008–2008
1 sentence

2008See also Justice v. State, 947 A.2d 1097 , 1102 n.23 (Del.2008) (discussing but not reaching the Pena issue decided here). 15 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
United States v. Stromberg green
ca2 · 1959
2 sentences

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

12020–2020
William Tallo v. United States green
ca1 · 1965
2 sentences

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

12020–2020
United States v. Jerry Gene Smith green
ca6 · 1968
2 sentences

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

2020See United States v. Poston, 430 F.2d 706 (6th Cir. 1970) (finding error where the trial court denied the defendant’s motions to strike and to declare a mistrial after a witness referenced the defendant’s probation status and no curative action was taken); United States v. Smith, 403 F.2d 74 (6th Cir. 1968) (finding a curative instruction to be insufficient where a witness referenced the defendant’s prior jail sentence); Tallo v. United States, 344 F.2d 467 (5th Cir. 1965) (finding error where the trial court denied trial counsel’s motion to strike and motion for a mistrial after a witness ref

12020–2020

Where else courts name it

TX 21 (1997–2022) CA 7 (1979–2026) UT 7 (1995–2022) DE 5 (2008–2021) NY 4 (2004–2017) FL 4 (2003–2010) GA 2 (2019–2019) WY 2 (2004–2004) NC 2 (2022–2022)

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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