unobjected-to error (Texas) · Go Syfert
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unobjected-to error in Texas

43 Texas opinions name it 3 courts 1986–2025 2 in the last five years

The cases below were cited by Texas 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 (17)

CaseFollowedCited
Almanza v. Stategreen
texcrimapp · 1985 · cited in 20 Texas opinions naming this issue, 1986–2021
2 sentences

2021This brings us to Appellant’s last, but related complaint, that the trial court erred by instructing the jury in the disjunctive that it could find him guilty of indecency by sexual contact as alleged in Count Two of the indictment if it found that he had touched V.T.’s breasts or her genitals.7 As Appellant admittedly did not object to the jury charge, we review this alleged error under the familiar Almanza standard, first determining whether error occurred, and if so, whether the unobjected-to error caused egregious harm to the defendant’s case.8 Almanza v. State, 686 S.W.2d 157, 171-74 (Tex

2015Compare Acts 1897, 25th Leg., ch. 21, p. 17 § 1 (“. . . which error shall be excepted to at the time of the trial, or on a motion for a new trial.”) with Acts 1913, 33rd Leg., ch. 138, p. 279, § 4 (“. . . and all objections to the charge, and on account of refusal or modification of special charges shall be made at the time of the trial.”). 4 Almanza, 686 S.W.2d at 171 . 2 short ‘egregious harm.’”5 Thus, it is only by embracing fundamental error—and labeling the requisite harm “egregious”—that this Court held that an unobjected-to claim of charge error is not forfeited by inaction.

1020
Barrera v. Stategreen
texcrimapp · 1998 · cited in 4 Texas opinions naming this issue, 2002–2002
2 sentences

2002Barrera v. State, 982 S.W.2d 415, 417 (Tex.Cr.App. 1998) (en banc).

2002Barrera v. State, 982 S.W.2d 415, 417 (Tex.Cr.App. 1998) (en banc).

44
Arizona v. Fulminantegreen
scotus · 1991 · cited in 3 Texas opinions naming this issue, 2010–2014
2 sentences

2014See Arizona v. Fulminante, 499 U.S. 279 , 309–10 (1991) (explaining that only in the case of fundamental or structural error is an unobjected-to error preserved for appeal); Rey v. State, 897 S.W.2d 333 , 344–45 (Tex. Crim.

2010See Arizona v. Fulminante , 499 U.S. 279, 309-10 (1991); Rey v. State , 897 S.W.2d 333, 344-45 (Tex. Crim.

33
Rey v. Stategreen
texcrimapp · 1995 · cited in 3 Texas opinions naming this issue, 2010–2014
2 sentences

2014See Arizona v. Fulminante, 499 U.S. 279 , 309–10 (1991) (explaining that only in the case of fundamental or structural error is an unobjected-to error preserved for appeal); Rey v. State, 897 S.W.2d 333 , 344–45 (Tex. Crim.

2010See Arizona v. Fulminante , 499 U.S. 279, 309-10 (1991); Rey v. State , 897 S.W.2d 333, 344-45 (Tex. Crim.

23
Taylor v. Stategreen
texcrimapp · 2011 · cited in 2 Texas opinions naming this issue, 2013–2015
2 sentences

2015Taylor v. State, 332 S.W.3d 483, 489 (Tex. Crim.

2013Taylor v. State, 332 S.W.3d 483, 489 (Tex. Crim.

22
Herron v. Stategreen
texcrimapp · 2002 · cited in 2 Texas opinions naming this issue, 2008–2011
2 sentences

2011See Herron v. State, 86 S.W.3d 621, 632 (Tex. Crim.

2008See id.1 Assuming, without deciding, that Richards was entitled to an accomplice- witness instruction, we will reverse only if the unobjected-to error caused “egregious” harm.2 See Herron v. State, 86 S.W.3d 621, 632 (Tex. Crim.

22
Tolbert v. Stategreen
texcrimapp · 2010 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010See Tolbert, 306 S.W.3d at 779 (citing Almanza v. State, 686 S.W.2d 157, 171 (Tex. Crim.

2010See Tolbert , 306 S.W.3d at 779 (citing Almanza v. State , 686 S.W.2d 157, 171 (Tex. Crim.

22
Pennington v. Stategreen
texcrimapp · 1985 · cited in 2 Texas opinions naming this issue, 2008–2008
2 sentences

2008See id. (“It is clear then that a general objection which does not distinctly specify the claimed error in the charge is not sufficient to preserve error.”); see also Almanza, 686 S.W.2d at 171 (setting out the “egregious harm” standard).

2008See id. ("It is clear then that a general objection which does not distinctly specify the claimed error in the charge is not sufficient to preserve error."); see also Almanza, 686 S.W.2d at 171 (setting out the "egregious harm" standard).

22
General Motors Corp. v. Irachetagreen
tex · 2005 · cited in 2 Texas opinions naming this issue, 2006–2006
2 sentences

2006Motors Corp. v. Iracheta , 161 S.W.3d 462, 472 (Tex. 2005), cited by GM, in which the Texas Supreme Court held that the trial court’s unobjected-to error in allowing the grandmother of the deceased plaintiffs to personally thank the all-Hispanic jury in Spanish was harmful. 20: Contrary to GM’s contentions, the introduction that occurred here is distinguishable from the grandmother’s comments in Iracheta .

2006Motors Corp. v. Iracheta, 161 S.W.3d 462, 472 (Tex.2005), cited by GM, in which the Texas Supreme Court held that the trial court's unobjected-to error in allowing the grandmother of the deceased plaintiffs to personally thank the all-Hispanic jury in Spanish was harmful. 20 .

22
Colburn v. Stategreen
texcrimapp · 1998 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See Colburn v. State, Becerra v. State Page 6 966 S.W.2d 511, 520 (Tex. Crim.

11
Soto v. Seven Seventeen HBE Corp.green
texapp · 2000 · cited in 1 Texas opinions naming this issue, 2012–2012
1 sentence

2012See Soto, 52 S.W.3d at 204 .

11
Lam v. Stategreen
texapp · 2000 · cited in 1 Texas opinions naming this issue, 2003–2003
2 sentences

2003See also Garcia, 919 S.W.2d at 397 (any error in this instruction was harmless beyond a reasonable doubt); Ward, 72 S.W.3d at 418-19 (any error in this unobjected-to instruction did not rise to level of egregious harm); Lam, 25 S.W.3d at 240-41 (same).

2003See also Garcia, 919 S.W.2d at 397 (any error in this instruction was harmless beyond a reasonable doubt); Ward, 72 S.W.3d at 418-19 (any error in this unobjected-to instruction did not rise to level of egregious harm); Lam, 25 S.W.3d at 240-41 (same). [1] Brown, at 801 (analyzing the instruction in this case with the "improper-judicial comment scale in mind") (internal quotes omitted).

11
Ward v. Stategreen
texapp · 2002 · cited in 1 Texas opinions naming this issue, 2003–2003
2 sentences

2003See also Garcia, 919 S.W.2d at 397 (any error in this instruction was harmless beyond a reasonable doubt); Ward, 72 S.W.3d at 418-19 (any error in this unobjected-to instruction did not rise to level of egregious harm); Lam, 25 S.W.3d at 240-41 (same).

2003See also Garcia, 919 S.W.2d at 397 (any error in this instruction was harmless beyond a reasonable doubt); Ward, 72 S.W.3d at 418-19 (any error in this unobjected-to instruction did not rise to level of egregious harm); Lam, 25 S.W.3d at 240-41 (same). [1] Brown, at 801 (analyzing the instruction in this case with the "improper-judicial comment scale in mind") (internal quotes omitted).

11
Garcia v. Stategreen
texcrimapp · 1996 · cited in 1 Texas opinions naming this issue, 2003–2003
2 sentences

2003See also Garcia, 919 S.W.2d at 397 (any error in this instruction was harmless beyond a reasonable doubt); Ward, 72 S.W.3d at 418-19 (any error in this unobjected-to instruction did not rise to level of egregious harm); Lam, 25 S.W.3d at 240-41 (same).

2003See also Garcia, 919 S.W.2d at 397 (any error in this instruction was harmless beyond a reasonable doubt); Ward, 72 S.W.3d at 418-19 (any error in this unobjected-to instruction did not rise to level of egregious harm); Lam, 25 S.W.3d at 240-41 (same). [1] Brown, at 801 (analyzing the instruction in this case with the "improper-judicial comment scale in mind") (internal quotes omitted).

11
Walker v. Stategreen
texapp · 1989 · cited in 1 Texas opinions naming this issue, 1994–1994
1 sentence

1994Walker v. State , 823 S.W.2d 302, 309 (Tex. App.--Tyler 1989), aff'd , 823 S.W.2d 247 (Tex. Crim.

11
White v. Stategreen
texapp · 1985 · cited in 1 Texas opinions naming this issue, 1986–1986
2 sentences

1986See also Smith v. State, 721 S.W.2d 844 (Tex.Crim.App.1986); White v. State, 699 S.W.2d 607, 615-18 (Tex.App.— Dallas 1985, no pet.).

1986See also Smith v. State, 721 S.W.2d 844 (Tex.Crim.App.1986); White v. State, 699 S.W.2d 607, 615-18 (Tex.App—Dallas 1985, no pet.).

11
Smith v. Stategreen
texcrimapp · 1986 · cited in 1 Texas opinions naming this issue, 1986–1986
2 sentences

1986See also Smith v. State, 721 S.W.2d 844 (Tex.Crim.App.1986); White v. State, 699 S.W.2d 607, 615-18 (Tex.App.— Dallas 1985, no pet.).

1986See also Smith v. State, 721 S.W.2d 844 (Tex.Crim.App.1986); White v. State, 699 S.W.2d 607, 615-18 (Tex.App—Dallas 1985, no pet.).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Igo v. State green
texcrimapp · 2006
2 sentences

2018Igo v. State, 210 S.W.3d 645 , 646–47 (Tex. Crim.

2015Igo v. State, 210 S.W.3d 645 , 646–47 (Tex. Crim.

22015–2018
Allen v. State green
texcrimapp · 2008
2 sentences

2012Allen, 253 S.W.3d at 264 & n.15.

2012Allen, 253 S.W.3d at 264 & n.15. 4 That argument focused on the boy’s response, “To go potty,” which he gave to the prosecutor’s question, “What do you use your privates for?” 5 Later, at the very end of the State’s rebuttal argument on closing, arguing appellant’s letter demonstrated his guilt, the prosecutor made the statements, “He did it intentionally.

22012–2012
C. B. v. Texas Department of Family and Protective Services green
texapp · 2013
1 sentence

2015Id. at 766 .

12015–2015
Walker v. State green
texcrimapp · 1991
1 sentence

1994Walker v. State , 823 S.W.2d 302, 309 (Tex. App.--Tyler 1989), aff'd , 823 S.W.2d 247 (Tex. Crim.

11994–1994
Browning v. State green
texcrimapp · 1986
1 sentence

1986Therefore, in light of Browning, supra, we remand this case to the Court of Appeals to decide by review of the entire record whether this unobjected-to error in the court’s charge *535 resulted in “egregious harm” to appellant.

11986–1986

Statutes the citing opinions construe

TX § Tex. Penal Code § 12.42 (7) TX § Tex. Penal Code § 21.11 (4) TX § Tex. Penal Code § 1.07 (3) TX § Tex. Penal Code § 2.03 (3) TX § Tex. Penal Code § 22.01 (3) TX § Tex. Penal Code § 9.31 (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

ID 82 (2011–2019) MN 68 (1988–2026) TX 43 (1986–2025) AZ 14 (1981–2024) WI 10 (1988–2024) OH 7 (2001–2026) MI 7 (1976–2023) MA 5 (1989–2018) KS 4 (1994–2025) IL 4 (1972–1993) FL 4 (2006–2026) MD 4 (2011–2026) CA 3 (1990–2020) NV 3 (2021–2022) NY 2 (1976–2000) CO 2 (2024–2025) IA 2 (2020–2020) DC 2 (2008–2014)

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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