two prong test (Minnesota) · Go Syfert
← Minnesota issues

two prong test in Minnesota

5 Minnesota opinions name it 2 courts 1988–2024 1 in the last five years

The cases below were cited by Minnesota 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 (5)

CaseFollowedCited
Strickland v. Washingtongreen
scotus · 1984 · cited in 2 Minnesota opinions naming this issue, 1988–2017
2 sentences

2017Nissalke v. State, 861 N.W.2d 88, 93-94 (Minn. 2015) (citing Strickland v. Washington, 3 466 U.S. 668, 687-88, 694 , 104 S. Ct. 2052, 2064, 2068 (1984)).

2017Nissalke v. State, 861 N.W.2d 88, 93-94 (Minn. 2015) (citing Strickland v. Washington, 3 466 U.S. 668, 687-88, 694 , 104 S. Ct. 2052, 2064, 2068 (1984)).

12
State v. Heaneygreen
minn · 2004 · cited in 1 Minnesota opinions naming this issue, 2024–2024
1 sentence

2024And the supreme court chose the “most-significant-relationship” test in Castillo-Alvarez because, consistent with prior caselaw considering the admissibility of evidence in criminal trials, the Minnesota rule has “both a procedural and substantive purpose.” Id. at 539 ; see also State v. Heaney, 689 N.W.2d 168, 170 (Minn. 2004) (“A conflict of laws concerning the admissibility of evidence protected by the physician-patient relationship is resolved by applying the two- prong test set forth in Restatement (Second) of Conflict of Laws § 139 (1971).”).

11
Nissalke v. Stategreen
minn · 2015 · cited in 1 Minnesota opinions naming this issue, 2017–2017
1 sentence

2017Nissalke v. State, 861 N.W.2d 88, 93-94 (Minn. 2015) (citing Strickland v. Washington, 3 466 U.S. 668, 687-88, 694 , 104 S. Ct. 2052, 2064, 2068 (1984)).

11
Bobo v. Stategreen
minn · 2012 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014See id.; Bobo, 820 N.W.2d at 516-517 (explaining that “[t]o receive an evidentiary hearing on a postconviction claim of ineffective assistance of appellate counsel, a defendant is required to allege facts that . . . would satisfy the two- prong test announced in Strickland v. Washington,” while “[t]o receive an evidentiary hearing on a . . . postconviction claim of newly discovered evidence, a defendant is required to allege facts that . . . would satisfy the four-prong test set forth in Rainer v. State”).

11
Gates v. Stategreen
minn · 1987 · cited in 1 Minnesota opinions naming this issue, 1988–1988
1 sentence

1988The defendant must affirmatively prove that his counsel’s representation “fell below an objective standard of reasonableness” and “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Gates v. State, 398 N.W.2d 558, 561 (Minn.1987) (quoting Strickland v. Washington, 466 U.S. 668, 694 , 104 S.Ct. 2052, 2068 , 80 L.Ed.2d 674 (1984) reh’g denied, 467 U.S. 1267 , 104 S.Ct. 3562 , 82 L.Ed.2d 864 (1984)).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
State v. Castillo-Alvarez green
minn · 2013
1 sentence

2024And the supreme court chose the “most-significant-relationship” test in Castillo-Alvarez because, consistent with prior caselaw considering the admissibility of evidence in criminal trials, the Minnesota rule has “both a procedural and substantive purpose.” Id. at 539 ; see also State v. Heaney, 689 N.W.2d 168, 170 (Minn. 2004) (“A conflict of laws concerning the admissibility of evidence protected by the physician-patient relationship is resolved by applying the two- prong test set forth in Restatement (Second) of Conflict of Laws § 139 (1971).”).

12024–2024
Angus v. State green
minn · 2005
1 sentence

2015Appellant carries the burden to demonstrate pretext through a two prong analysis: (1) “the proffered race-neutral reason is not the real reason for the strike” and (2) “the real reason was the race of the veniremember.” Angus, 695 N.W.2d at 117 .

12015–2015
Bose Corp. v. Consumers Union of United States, Inc. green
scotus · 1984
1 sentence

1988The defendant must affirmatively prove that his counsel’s representation “fell below an objective standard of reasonableness” and “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Gates v. State, 398 N.W.2d 558, 561 (Minn.1987) (quoting Strickland v. Washington, 466 U.S. 668, 694 , 104 S.Ct. 2052, 2068 , 80 L.Ed.2d 674 (1984) reh’g denied, 467 U.S. 1267 , 104 S.Ct. 3562 , 82 L.Ed.2d 864 (1984)).

11988–1988

Where else courts name it

OH 305 (1990–2026) TX 171 (1970–2025) TN 108 (1994–2024) NJ 57 (1987–2026) LA 52 (1983–2025) CT 47 (1985–2024) IL 47 (1986–2026) IN 30 (1980–2023) FL 29 (1988–2025) PA 28 (1977–2019) WA 27 (1999–2024) MS 17 (1984–2006) CA 16 (1983–2025) MO 15 (1986–2021) GA 14 (1980–2021) KS 14 (2020–2026) NC 12 (1978–2025) SC 9 (1986–2013) DE 8 (1982–2024) OK 8 (1986–2018) NM 8 (1974–2025) WI 7 (1991–2026) AR 7 (2016–2026) ME 6 (1987–2021) SD 6 (1997–2024) MD 6 (1983–2020) MT 6 (1991–2017) ID 5 (1999–2023) HI 5 (2003–2020) KY 5 (1995–2026) WV 5 (1981–2021) MN 5 (1988–2024) NY 5 (2002–2016) RI 3 (1995–2011) DC 3 (1984–2000) MA 3 (2000–2026) NV 3 (2009–2016) VA 3 (1997–2007) AZ 2 (1984–1996) UT 2 (1991–2019) CO 2 (1996–2009)

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