harmful error (Florida) · Go Syfert
← Florida issues

harmful error in Florida

42 Florida opinions name it 2 courts 1928–2026 2 in the last five years

The cases below were cited by Florida 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 (34)

CaseFollowedCited
Hagan v. Sun Bank of Mid-Floridagreen
fladistctapp · 1996 · cited in 3 Florida opinions naming this issue, 2000–2019
2 sentences

2019Hagan v. Sun Bank of Mid-Florida, N.A., 666 So. 2d 580, 584 (Fla. 2d DCA 1996) (emphasis added), disapproved of on other grounds by Murphy v. Int’l Robotic Sys., Inc., 766 So.2d 1010 (Fla. 2000).

2014Relief is granted for a fundamental error not because the party has preserved a right to relief from a harmful error, but because, the public’s confidence in our system of justice would be seriously weakened if the courts failed to give relief as a matter of grace for certain, very limited and serious mistakes.” Hagan v. Sun Bank of Mid-Florida, N.A, 666 So.2d 580, 584 (Fla. 2d DCA 1996) disapproved of on other grounds by Murphy v. Int’l Robotic Sys., Inc., 766 So.2d 1010 (Fla.2000).

33
Ghay v. Ghaygreen
fladistctapp · 2007 · cited in 2 Florida opinions naming this issue, 2008–2010
2 sentences

2010In Ghay v. Ghay, 954 So.2d 1186, 1190 (Fla. 2d DCA 2007), this court noted that it was much more difficult to establish that a trial court abused its discretion or that a harmful error of law occurred in an order awarding temporary alimony.

2008See Ghay v. Ghay, 954 So.2d 1186, 1190 (Fla. 2d DCA 2007) ("[I]t is undoubtedly more difficult to establish an abuse of discretion or a harmful error of law in a temporary order.

22
Scoggins v. Stategreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024“Fundamental error has been defined as one that goes to the essence of a fair and impartial trial, error so fundamentally unfair as to amount to a denial of due process.” Scoggins v. State, 691 So. 2d 1185, 1189 (Fla. 4th DCA 1997).

11
Washington v. Stategreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2020–2020
1 sentence

2020See Washington v. State, 955 So. 2d 1165, 1173 (Fla. 1st DCA 2007) (holding that the excusal of a juror for asking “too 13 many questions” was not harmless, because “the reconfiguration of the jury panel is the very error that must be corrected”).

11
Shaun D. Reed, AKA Shawn D. Reed v. State of Floridagreen
fladistctapp · 2017 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018See Reed v. State, 208 So. 3d 1231, 1234 (Fla. 1st DCA 2017) (holding the lack of evidence made stealthy-entry instruction erroneous, but harmless error where State and 2 defense “barely mentioned” the inference of intent in their respective closing arguments).

11
Khadafy Kareem Mullens v. State of Floridagreen
fla · 2016 · cited in 1 Florida opinions naming this issue, 2018–2018
2 sentences

2018See Mullens, 197 So. 3d at 40 .

2018See Mullens , 197 So.3d at 40 .

11
People v. Crutchfieldgreen
illappct · 2004 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

11
Kormondy v. Stategreen
fla · 1997 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., Perez, 919 So.2d at 381-82 (remanding for new penalty phase after the erroneous finding of HAC was considered harmful in light of the historical weight associated with that aggravating circumstance); Kormondy v. State, 703 So.2d 454, 462-63 (Fla. 1997) (remanding for new penalty phase for harmful admission of prejudicial, irrelevant evidence in the penalty phase); James v. State, 615 So.2d 668, 669 (Fla. 1993) (remanding for new penalty phase following invalidation of HAC instruction by Espinosa v. Florida, 505 U.S. 1079 , 112 S.Ct. 2926 , 120 L.Ed.2d 854 (1992), for defendant who h

11
James v. Stategreen
fla · 1993 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., Perez, 919 So.2d at 381-82 (remanding for new penalty phase after the erroneous finding of HAC was considered harmful in light of the historical weight associated with that aggravating circumstance); Kormondy v. State, 703 So.2d 454, 462-63 (Fla. 1997) (remanding for new penalty phase for harmful admission of prejudicial, irrelevant evidence in the penalty phase); James v. State, 615 So.2d 668, 669 (Fla. 1993) (remanding for new penalty phase following invalidation of HAC instruction by Espinosa v. Florida, 505 U.S. 1079 , 112 S.Ct. 2926 , 120 L.Ed.2d 854 (1992), for defendant who h

11
Ritchie v. Stategreen
ind · 2004 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

2017App. Ct. 2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 .11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

11
Perez v. Stategreen
fla · 2006 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., Perez, 919 So.2d at 381-82 (remanding for new penalty phase after the erroneous finding of HAC was considered harmful in light of the historical weight associated with that aggravating circumstance); Kormondy v. State, 703 So.2d 454, 462-63 (Fla. 1997) (remanding for new penalty phase for harmful admission of prejudicial, irrelevant evidence in the penalty phase); James v. State, 615 So.2d 668, 669 (Fla. 1993) (remanding for new penalty phase following invalidation of HAC instruction by Espinosa v. Florida, 505 U.S. 1079 , 112 S.Ct. 2926 , 120 L.Ed.2d 854 (1992), for defendant who h

11
Brice v. Stategreen
del · 2003 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

11
Atkins v. Stategreen
fla · 1984 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., Perez, 919 So.2d at 381-82 (remanding for new penalty phase after the erroneous finding of HAC was considered harmful in light of the historical weight associated with that aggravating circumstance); Kormondy v. State, 703 So.2d 454, 462-63 (Fla. 1997) (remanding for new penalty phase for harmful admission of prejudicial, irrelevant evidence in the penalty phase); James v. State, 615 So.2d 668, 669 (Fla. 1993) (remanding for new penalty phase following invalidation of HAC instruction by Espinosa v. Florida, 505 U.S. 1079 , 112 S.Ct. 2926 , 120 L.Ed.2d 854 (1992), for defendant who h

11
Banks v. Stategreen
fla · 2010 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Cf. Banks v. State, 46 So. 3d 989, 998-99 (Fla. -5- 2010) (holding there was no error in admission of highly probative soundless surveillance video despite prejudice of showing a violent but short-lived crime occur); Singleton v. State, 783 So. 2d 970, 976 (Fla. 2001) (holding there was no error in admission of highly probative video despite prejudice of showing defendant in prison uniform).1 In allowing prejudicial evidence in this case, the court committed harmful error.

11
Singleton v. Stategreen
fla · 2001 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Cf. Banks v. State, 46 So. 3d 989, 998-99 (Fla. -5- 2010) (holding there was no error in admission of highly probative soundless surveillance video despite prejudice of showing a violent but short-lived crime occur); Singleton v. State, 783 So. 2d 970, 976 (Fla. 2001) (holding there was no error in admission of highly probative video despite prejudice of showing defendant in prison uniform).1 In allowing prejudicial evidence in this case, the court committed harmful error.

11
Lewis v. Stategreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013See Masaka v. State, 4 So.3d 1274, 1285-86 (Fla. 2d DCA 2009) (noting that a harmful error occurs with a jury instruction that is “capable of misleading the jury in such a way as to prejudice the defendant’s right to a fair trial” (quoting Lewis v. State, 693 So.2d 1055, 1057 (Fla. 4th DCA 1997))).

11
Masaka v. Stategreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013See Masaka v. State, 4 So.3d 1274, 1285-86 (Fla. 2d DCA 2009) (noting that a harmful error occurs with a jury instruction that is “capable of misleading the jury in such a way as to prejudice the defendant’s right to a fair trial” (quoting Lewis v. State, 693 So.2d 1055, 1057 (Fla. 4th DCA 1997))).

11
Mercer v. Rainegreen
fla · 1983 · cited in 1 Florida opinions naming this issue, 2012–2012
11
Ross v. Stategreen
fladistctapp · 1985 · cited in 1 Florida opinions naming this issue, 2008–2008
11
Straight v. Stategreen
fla · 1981 · cited in 1 Florida opinions naming this issue, 2008–2008
11
City of Niceville v. Hardygreen
fladistctapp · 1964 · cited in 1 Florida opinions naming this issue, 2008–2008
11
Dunlap v. Stategreen
fladistctapp · 1981 · cited in 1 Florida opinions naming this issue, 2008–2008
11
Hotel Halceyon Corp. v. the Guardian Trust Co.green
fla · 1932 · cited in 1 Florida opinions naming this issue, 2001–2001
11
Arbuthnot v. Brooks-Scanlon Corp.green
fla · 1931 · cited in 1 Florida opinions naming this issue, 2001–2001
11
Maharaj v. Stategreen
fla · 1996 · cited in 1 Florida opinions naming this issue, 2001–2001
11
Kelley v. Stategreen
fla · 1986 · cited in 1 Florida opinions naming this issue, 2001–2001
11
Gonzalez v. Stategreen
fla · 1997 · cited in 1 Florida opinions naming this issue, 2001–2001
11
Donaldson v. Stategreen
fla · 1998 · cited in 1 Florida opinions naming this issue, 2001–2001
11
Wuornos v. Stategreen
fla · 1996 · cited in 1 Florida opinions naming this issue, 2001–2001
11
Wilding v. Stategreen
fla · 1996 · cited in 1 Florida opinions naming this issue, 2000–2000
11
State v. DiGuiliogreen
fla · 1986 · cited in 1 Florida opinions naming this issue, 1999–1999
11
Le Fevre v. Beargreen
fladistctapp · 1959 · cited in 1 Florida opinions naming this issue, 1980–1980
11
Loftin v. Skeltongreen
fla · 1943 · cited in 1 Florida opinions naming this issue, 1959–1959
11
Jordan v. Stategreen
fla · 1932 · cited in 1 Florida opinions naming this issue, 1958–1958
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (38)

CaseCitedYears
Murphy v. International Robotic Systems, Inc. green
fla · 2000
2 sentences

2019Hagan v. Sun Bank of Mid-Florida, N.A., 666 So. 2d 580, 584 (Fla. 2d DCA 1996) (emphasis added), disapproved of on other grounds by Murphy v. Int’l Robotic Sys., Inc., 766 So.2d 1010 (Fla. 2000).

2014Relief is granted for a fundamental error not because the party has preserved a right to relief from a harmful error, but because, the public’s confidence in our system of justice would be seriously weakened if the courts failed to give relief as a matter of grace for certain, very limited and serious mistakes.” Hagan v. Sun Bank of Mid-Florida, N.A, 666 So.2d 580, 584 (Fla. 2d DCA 1996) disapproved of on other grounds by Murphy v. Int’l Robotic Sys., Inc., 766 So.2d 1010 (Fla.2000).

22014–2019
Ruby Saunders, etc. v. Willis Dickens, M.D. green
fla · 2014
2 sentences

2018Id. at 442-43 .

2018Id. at 442-43 .

22018–2018
Cavaliere v. State green
fladistctapp · 2014
1 sentence

2026For example, in Cavaliere, 147 So. 3d at 630 , this court held that harmful error occurred when a detective improperly vouched for a child victim by telling the jury what truth qualification is, that the child victim had been truth qualified, and that "by looking at her and kind of getting a feel for her I could tell that, you know, she was— she was acting appropriately.

12026–2026
Sims v. State green
fladistctapp · 2013
1 sentence

2024Cf. Sims v. State, 135 So. 3d 1098 , 1101–02 (Fla. 2d DCA 2013) (describing fundamental error as the shifting of the burden to the defendant to prove a harmful error while the harmless error analysis puts the burden on the State to prove that the error was harmless beyond a reasonable doubt).

12024–2024
Espinosa v. Florida green
scotus · 1992
2 sentences

2017See, e.g., Perez, 919 So.2d at 381-82 (remanding for new penalty phase after the erroneous finding of HAC was considered harmful in light of the historical weight associated with that aggravating circumstance); Kormondy v. State, 703 So.2d 454, 462-63 (Fla. 1997) (remanding for new penalty phase for harmful admission of prejudicial, irrelevant evidence in the penalty phase); James v. State, 615 So.2d 668, 669 (Fla. 1993) (remanding for new penalty phase following invalidation of HAC instruction by Espinosa v. Florida, 505 U.S. 1079 , 112 S.Ct. 2926 , 120 L.Ed.2d 854 (1992), for defendant who h

2017See, e.g., Perez, 919 So.2d at 381-82 (remanding for new penalty phase after the erroneous finding of HAC was considered harmful in light of the historical weight associated with that aggravating circumstance); Kormondy v. State, 703 So.2d 454, 462-63 (Fla. 1997) (remanding for new penalty phase for harmful admission of prejudicial, irrelevant evidence in the penalty phase); James v. State, 615 So.2d 668, 669 (Fla. 1993) (remanding for new penalty phase following invalidation of HAC instruction by Espinosa v. Florida, 505 U.S. 1079 , 112 S.Ct. 2926 , 120 L.Ed.2d 854 (1992), for defendant who h

12017–2017
Gross v. Lyons green
fladistctapp · 1998
2 sentences

2017In Gross v. Lyons, 721 So. 2d 304 (Fla. 4th DCA 1998), the Fourth District Court of Appeal stated, “Reversible error occurs when an instruction is not only an erroneous or incomplete statement of the law, but is also confusing or misleading.” Id. at 306 ; see Holman Live Stock Co. v. Louisville & N.R.

2017In Gross v. Lyons, 721 So. 2d 304 (Fla. 4th DCA 1998), the Fourth District Court of Appeal stated, “Reversible error occurs when an instruction is not only an erroneous or incomplete statement of the law, but is also confusing or misleading.” Id. at 306 ; see Holman Live Stock Co. v. Louisville & N.R.

12017–2017
Elledge v. State green
fla · 1977
1 sentence

2017See, e.g., Perez, 919 So.2d at 381-82 (remanding for new penalty phase after the erroneous finding of HAC was considered harmful in light of the historical weight associated with that aggravating circumstance); Kormondy v. State, 703 So.2d 454, 462-63 (Fla. 1997) (remanding for new penalty phase for harmful admission of prejudicial, irrelevant evidence in the penalty phase); James v. State, 615 So.2d 668, 669 (Fla. 1993) (remanding for new penalty phase following invalidation of HAC instruction by Espinosa v. Florida, 505 U.S. 1079 , 112 S.Ct. 2926 , 120 L.Ed.2d 854 (1992), for defendant who h

12017–2017
People v. Crutchfield green
illappct · 2004
1 sentence

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

12017–2017
Green v. State green
fladistctapp · 1999
1 sentence

2017This court found this was not an amendment but rather “the filing of a new and entirely different offense.” Id.

12017–2017
State v. Galindo green
neb · 2009
2 sentences

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

2017App. Ct. 2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 .11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

12017–2017
State v. Ring green
ariz · 2003
1 sentence

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

12017–2017
State v. Lovelace green
idaho · 2004
1 sentence

2017E.g., Ring II, 65 P.3d at 945 ; Brice v. State, 815 A.2d 314, 321 (Del. 2003); Lovelace, 90 P.3d at 302-03 ; People v. Crutchfield, 353 Ill.App.3d 1014 , 289 Ill.Dec. 731 , 820 N.E.2d 507, 517 (2004) (finding no ex post facto violation in resentencing a defendant under procedures revised pursuant to Apprendi); Ritchie v. State, 809 N.E.2d 258, 264 (Ind. 2004); Galindo, 774 N.W.2d at 210-11 . 11 Finally, this Court has historically chosen to remand for a new penalty phase when a harmful error occurs during the original penalty phase.

12017–2017
Donna Horwitz v. State green
fladistctapp · 2015
1 sentence

2016Horwitz, 189 So.3d at 800 n. 1, 804.

12016–2016
Bonifay v. State green
fla · 1996
12011–2011
Public Health Trust of Dade Cty. v. Valcin green
fla · 1987
12009–2009
Galindez v. State green
fla · 2007
12007–2007
Cardenas v. State green
fla · 2004
12006–2006
State v. Bender green
fla · 1980
12006–2006
Strickland v. Washington green
scotus · 1984
12001–2001
Conley v. State green
fla · 1993
12000–2000
State v. Baird green
fla · 1990
12000–2000
State v. Sanborn green
fla · 1988
11990–1990
Rauso v. State green
fladistctapp · 1983
11990–1990
Williamson v. State green
fladistctapp · 1987
11990–1990
Eisner v. Eisner green
fladistctapp · 1987
11990–1990
State v. Murray green
fla · 1984
11989–1989
Brown v. State green
fla · 1968
11981–1981
Tallahassee Democrat, Inc. v. Pogue neutral
fladistctapp · 1973
11980–1980
Swindell v. Hellkamp green
fla · 1970
11971–1971
Simpson v. State green
fladistctapp · 1968
11970–1970
Scarpati v. State green
fladistctapp · 1969
11970–1970
Espinola v. State neutral
fla · 1955
11966–1966
Burnette v. State green
fla · 1963
11966–1966
State v. Febre green
fla · 1945
11963–1963
Lawson v. Loftin green
fla · 1945
11959–1959
Conran v. State green
fla · 1944
11959–1959
Powell v. American Sumatra Tobacco Company green
fla · 1944
11959–1959
Garner v. State green
· 1891
11928–1928

Statutes the citing opinions construe

FL § 59.041 (5) FL § 921.141 (4) FL § 775.082 (3) FL § 90.403 (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

TX 118 (1973–2026) GA 73 (1948–2025) FL 42 (1928–2026) UT 39 (1989–2026) CT 27 (1932–2025) NJ 17 (2014–2025) IN 15 (1896–2018) OH 11 (1999–2008) ME 8 (1976–2024) NY 6 (1905–2022) PA 5 (1918–2009) TN 5 (1962–2003) MS 4 (2001–2006) IL 4 (1971–2012) MA 3 (1923–2019) MI 3 (1904–2021) HI 2 (1995–2018) DC 2 (1984–2006) MD 2 (2011–2014) CA 2 (2013–2026) NC 2 (2021–2021)

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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