adequacy defense (Virginia) · Go Syfert
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adequacy defense in Virginia

5 Virginia opinions name it 2 courts 1985–2026 1 in the last five years

The cases below were cited by Virginia 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 (3)

CaseFollowedCited
Kinard v. Commonwealthgreen
vactapp · 1993 · cited in 2 Virginia opinions naming this issue, 2000–2001
2 sentences

2000It failed to warn him that if he rejected professional assistance, he would be responsible for the adequacy of his defense and would suffer the consequences of any inadequacy. 16 Va. App. at 527 , 431 S.E.2d at 86 .

2000It failed to warn him that if he rejected professional assistance, he would be responsible for the adequacy of his defense and would suffer the consequences of any inadequacy. 16 Va. App. at 527 , 431 S.E.2d at 86 .

12
Commonwealth v. Swann (ORDER)green
va · 2015 · cited in 1 Virginia opinions naming this issue, 2026–2026
1 sentence

2026Consequently, we do not consider the adequacy of the hearing on the masking motion or the possibility that allowing the masking implied to the jury that House was “dangerous” or “guilty.” See generally Baez v. Commonwealth, 303 Va. 421 , 430 n.4, 433 n.5 (2024) (recognizing the principle requiring an appellate court to “decide cases ‘on the best and narrowest ground[] available,’” including “avoid[ing]” the “‘unnecessary adjudication of . . . constitutional issue[s],’” and limiting analysis to the aspects of an issue presented in argument on brief (quoting Commonwealth v. Swann, 290 Va. 194, 1

11
Roadcap v. Commonwealthgreen
vactapp · 2007 · cited in 1 Virginia opinions naming this issue, 2026–2026
1 sentence

2026See Roadcap v. Commonwealth, 50 Va. App. 732, 743-44 (2007), cited with approval in Stephen R.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Brisson v. Minneapolis Baseball & Athletic Ass'n green
minn · 1932
1 sentence

2003As explained in Brisson v. Minneapolis Baseball & Athletic Ass’n, 240 N.W. 903 (Minn. 1932): No one of ordinary intelligence could see many innings of the ordinary league game without coming to a full realization that batters cannot, and do not, control the direction of the ball which they strike and that foul tips or liners may go in an entirely unexpected direction. [One] could not hear the bat strike the ball many times without realizing that the ball was a hard object.

12003–2003
Miranda v. Arizona green
scotus · 1966
1 sentence

1985Moreover, he conceded that Miranda v. Arizona, 384 U.S. 436 (1966), contains no “ironclad requirements” concerning the language that must be used to convey to defendant his rights under the Fifth Amendment.

11985–1985

Where else courts name it

TX 172 (1935–2026) NY 130 (1953–2026) CA 78 (1954–2026) IL 57 (1970–2026) WA 48 (1968–2026) PA 46 (1971–2023) IN 43 (1979–2024) FL 43 (1972–2026) NJ 31 (1955–2025) LA 31 (1954–2024) MI 27 (1963–2022) MA 25 (1974–2025) OH 24 (1974–2026) MN 22 (1984–2024) OR 21 (1943–2024) NV 21 (1983–2022) MS 20 (1969–2017) CO 16 (1976–2021) WI 15 (1972–2026) MO 15 (1958–2019) CT 14 (1950–2016) AZ 14 (1947–2024) AL 13 (1983–2013) KS 13 (1984–2026) NM 13 (1975–2015) AR 12 (1992–2022) TN 11 (1985–2022) DC 11 (1968–2025) UT 11 (1989–2024) GA 10 (1982–2025) IA 10 (1986–2014) DE 9 (1985–2023) KY 9 (1968–2024) RI 9 (2000–2026) MD 8 (1968–2012) OK 7 (1975–2010) ID 6 (1979–2013) AK 6 (1973–2018) VA 5 (1985–2026) VT 5 (1990–2026) ND 5 (1909–1997) NC 4 (1975–2012) WY 4 (1992–2019) WV 4 (1979–2018) SC 4 (1973–2008) ME 3 (1981–2013) HI 3 (1999–2007) MT 3 (2000–2010) VI 2 (2002–2005)

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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