175 Arkansas opinions name it 2 courts 1986–2026 24 in the last five years
The cases below were cited by Arkansas 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.
| Case | Followed | Cited |
|---|---|---|
Walker v. Stategreen2 sentences2016Strickland v. Washington, 466 U.S. 668 , |a104 S.Ct. 2052, 80 L.Ed.2d 674 (1984); Walker v. State, 367 Ark. 523 , 241 S.W.3d 734 (2006) (per curiam). 2016Strickland v. Washington, 466 U.S. 668 , |a104 S.Ct. 2052, 80 L.Ed.2d 674 (1984); Walker v. State, 367 Ark. 523 , 241 S.W.3d 734 (2006) (per curiam). | 3 | 11 |
State v. Franklingreen2 sentences2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). 2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). | 3 | 3 |
Strickland v. Washingtongreen2 sentences2025Strickland Standard Our standard for ineffective-assistance-of-counsel claims is the two-prong analysis set forth in Strickland v. Washington, 466 U.S. 668 (1984). 2022Strickland Standard Our standard for ineffective-assistance-of-counsel claims is the two-prong analysis set forth in Strickland v. Washington, 466 U.S. 668 (1984). | 2 | 27 |
Hill v. Lockhartgreen2 sentences2013The United States Supreme Court has indicated that an inquiry into whether a plea is rejected, or in Appellee’s case entered, knowingly and voluntarily is not the correct means by which to address a claim of ineffective assistance of counsel; rather, pursuant to Hill v. Lockhart, 474 U.S. 52 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985), the Strickland test should be applied in assessing a claim of ineffective assistance of counsel arising out of the plea-negotiation process. 2013The United States Supreme Court has indicated that an inquiry into whether a plea is rejected, or in Appellee’s case entered, knowingly and voluntarily is not the correct means by which to address a claim of ineffective assistance of counsel; rather, pursuant to Hill v. Lockhart, 474 U.S. 52 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985), the Strickland test should be applied in assessing a claim of ineffective assistance of counsel arising out of the plea-negotiation process. | 2 | 10 |
Howard v. Stategreen2 sentences2016See id. at 5, 470 S.W.3d at 275 (citing Howard v. State, 367 Ark. 18 , 238 S.W.3d 24 (2006)).3 Unless a petitioner under Rule 37 makes both required showings under the Strickland analysis, it cannot be said that the conviction resulted from a breakdown in the adversarial process that renders the result unreliable. 2016See id. at 5, 470 S.W.3d at 275 (citing Howard v. State, 367 Ark. 18 , 238 S.W.3d 24 (2006)).3 Unless a petitioner under Rule 37 makes both required showings under the Strickland analysis, it cannot be said that the conviction resulted from a breakdown in the adversarial process that renders the result unreliable. | 2 | 6 |
Breeden v. Stategreen2 sentences2018Breeden v. State , 2014 Ark. 159 , at 6-7, 432 S.W.3d 618 , 624 (per curiam). 2018Breeden v. State , 2014 Ark. 159 , at 6-7, 432 S.W.3d 618 , 624 (per curiam). | 2 | 5 |
Croy v. Stategreen2 sentences2015Id.-, see Cray v. State, 2011 Ark. 284 , 383 S.W.3d 367 (per curiam) (holding it is incumbent on a defendant claiming ineffective assistance for failure to call a witness to show that the error denied him a fair trial). 2015Id.-, see Cray v. State, 2011 Ark. 284 , 383 S.W.3d 367 (per curiam) (holding it is incumbent on a defendant claiming ineffective assistance for failure to call a witness to show that the error denied him a fair trial). | 2 | 5 |
Anderson v. Stategreen2 sentences2016See, e.g., Anderson v. State, 2015 Ark. 18 , 454 S.W.3d 212 (per curiam). 2016See, e.g., Anderson v. State, 2015 Ark. 18 , 454 S.W.3d 212 (per curiam). | 2 | 4 |
Noel v. Stategreen2 sentences2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). 2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). | 2 | 3 |
Johnson v. Stategreen2 sentences2005Moreover, we held in Johnson v. State, 356 Ark. 534 , 157 S.W.3d 151 (2004), that failure to preserve an issue for federal habeas review is not the prejudice contemplated by the Strickland test, which requires a reasonable probability that the outcome at trial would have been different. 2005Moreover, we held in Johnson v. State, 356 Ark. 534 , 157 S.W.3d 151 (2004), that failure to preserve an issue for federal habeas review is not the prejudice contemplated by the Strickland test, which requires a reasonable probability that the outcome at trial would have been different. | 2 | 3 |
Strain v. Stategreen2 sentences2017Strain v. State, 2012 Ark. 42, at 2 , 394 S.W.3d 294, 297 (per curiam). 2017Strain v. State, 2012 Ark. 42, at 2 , 394 S.W.3d 294, 297 (per curiam). | 2 | 3 |
| Taylor v. Stategreen | 2 | 2 |
| Chunestudy v. Stategreen | 2 | 2 |
| Huls v. Stategreen | 2 | 2 |
| Thomas v. Stategreen | 2 | 2 |
Lowe v. Stategreen2 sentences2026Id. 2026Id. | 1 | 16 |
State v. Hardingreen2 sentences2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). 2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). | 1 | 5 |
Sartin v. Stategreen2 sentences2021Id. 2021Id. | 1 | 5 |
State v. Barrettgreen2 sentences2012See id. 2012See id. | 1 | 4 |
Lafler v. Coopergreen2 sentences2025Id. 2025Id. | 1 | 3 |
Anderson v. Stategreen2 sentences2023Anderson v. State, 2011 Ark. 488, at 5 , 385 S.W.3d 783, 788 . 8 We agree that Morgan failed to satisfy either prong of the Strickland test. 2023Anderson v. State, 2011 Ark. 488, at 5 , 385 S.W.3d 783, 788 . 8 We agree that Morgan failed to satisfy either prong of the Strickland test. | 1 | 2 |
Stiggers v. Stategreen2 sentences2020See Stiggers v. State, 2014 Ark. 184 , 433 S.W.3d 252 (noting that the petitioner must satisfy both prongs of the Strickland test, and it is not necessary to determine whether counsel was deficient if the petitioner fails to demonstrate prejudice as to an alleged error). 2020See Stiggers v. State, 2014 Ark. 184 , 433 S.W.3d 252 (noting that the petitioner must satisfy both prongs of the Strickland test, and it is not necessary to determine whether counsel was deficient if the petitioner fails to demonstrate prejudice as to an alleged error). | 1 | 2 |
| Clayton v. Stategreen | 1 | 2 |
| State v. Smithgreen | 1 | 2 |
| Wertz v. Stategreen | 1 | 2 |
| Magness v. Stategreen | 1 | 2 |
| Mathis v. Stategreen | 1 | 2 |
| Vickers v. Stategreen | 1 | 2 |
| Huff v. Stategreen | 1 | 2 |
| Turner v. Stategreen | 1 | 1 |
| Feuget v. Stategreen | 1 | 1 |
| Nashville Livestock Commission v. Coxgreen | 1 | 1 |
| Jones v. Arkansas Department of Human Servicesgreen | 1 | 1 |
| Wainwright v. Stategreen | 1 | 1 |
| Young v. Stategreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Arkansas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Hickey v. State
green
2 sentences2014Id. 2014Id. | 8 | 2013–2014 |
Edward Joseph Reynolds v. State of Arkansas
green
2 sentences2025Reynolds v. State, 2020 Ark. 174 , 599 S.W.3d 120 . 2025Reynolds v. State, 2020 Ark. 174 , 599 S.W.3d 120 . | 7 | 2021–2025 |
Montgomery v. State
green
2 sentences2021Id. 2021Id. | 6 | 2012–2021 |
Springs v. State
green
2 sentences2014Id. (citing Strickland, 466 U.S. at 697 ). 2014Id. (citing Strickland, 466 U.S. at 697 ). | 6 | 2013–2014 |
Harrison v. State
green
2 sentences2013Harrison v. State, 371 Ark. 474 , 268 S.W.3d 324 (2007). 2013Harrison v. State, 371 Ark. 474 , 268 S.W.3d 324 (2007). | 5 | 2010–2013 |
Van Winkle v. State
green
2 sentences2022Van Winkle [v. State], 2016 Ark. 98 , at 6–7, 486 S.W.3d at 784 . 2022Van Winkle [v. State], 2016 Ark. 98 , at 6–7, 486 S.W.3d at 784 . | 3 | 2017–2022 |
Mancia v. State
green
2 sentences2020Mancia, 2015 Ark. 115, at 5 , 459 S.W.3d at 264 . 2020Mancia, 2015 Ark. 115, at 5 , 459 S.W.3d at 264 . | 3 | 2018–2020 |
Holloway v. State
green
2 sentences2019Holloway v. State, 2013 Ark. 140 , 426 S.W.3d 462 . 2019Holloway v. State, 2013 Ark. 140 , 426 S.W.3d 462 . | 3 | 2014–2019 |
Decay v. State
green
2 sentences2016E.g., Decay v. State, 2014 Ark. 387 , 441 S.W.3d 899 . 2016E.g., Decay v. State, 2014 Ark. 387 , 441 S.W.3d 899 . | 3 | 2015–2016 |
Sales v. State
green
2 sentences2016Sales v. State, 2014 Ak. 384, 441 S.W.3d 883 . 2016Sales v. State, 2014 Ak. 384, 441 S.W.3d 883 . | 3 | 2015–2016 |
Caery v. State
neutral
2 sentences2014A petitioner seeking postconviction relief on a claim of ineffective assistance that is based on the 3 Cite as 2014 Ark. 247 failure of counsel to make a motion to sever is required to establish that counsel could have made a successful argument in order to demonstrate the prejudice required under the Strickland test. 2014A petitioner seeking postconviction relief on a claim of ineffective assistance that is based on the 3 Cite as 2014 Ark. 247 failure of counsel to make a motion to sever is required to establish that counsel could have made a successful argument in order to demonstrate the prejudice required under the Strickland test. | 3 | 2014–2014 |
Huddleston v. State
green
2 sentences2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). 2025Whiteside, supra; see also, e.g., Noel v. State, 342 Ark. 35 , 26 S.W.3d 123 (2000); Huddleston v. State, 339 Ark. 266 , 5 S.W.3d 46 (1999); see also State v. Franklin, 351 Ark. 131 , 89 S.W.3d 865 (2002); State v. Hardin, 347 Ark. 62 , 60 S.W.3d 397 (2001) (holding that it was erroneous for the circuit court to entertain a claim of cumulative error in a Strickland analysis). | 2 | 2024–2025 |
| Tollett v. Henderson green | 2 | 2016–2017 |
| Doty v. State green | 2 | 2016–2016 |
| State v. Brown green | 2 | 2010–2015 |
| Adams v. State green | 2 | 2014–2014 |
| Moten v. State green | 2 | 2013–2013 |
| State v. Slocum green | 2 | 2000–2001 |
| Monts v. State green | 2 | 1998–2001 |
| Crockett v. State green | 2 | 1991–1997 |
| Florida v. Nixon green | 1 | 2026–2026 |
| Norris v. State green | 1 | 2026–2026 |
| Brad Hunter Smith v. State of Arkansas green | 1 | 2026–2026 |
| Perry v. State green | 1 | 2026–2026 |
| Houghton v. State green | 1 | 2024–2024 |
| Davenport v. State green | 1 | 2022–2022 |
| Jamett v. State green | 1 | 2020–2020 |
| Williams v. State green | 1 | 2020–2020 |
| Fred L. Williams v. State of Arkansas green | 1 | 2020–2020 |
| Bond v. State green | 1 | 2019–2019 |
| Liggins v. State green | 1 | 2019–2019 |
| Gordon v. State green | 1 | 2019–2019 |
| McClinton v. State green | 1 | 2019–2019 |
| MARK DAVID JOHNSON v. STATE OF ARKANSAS green | 1 | 2018–2018 |
| Paige v. State green | 1 | 2018–2018 |
| Osburn v. State neutral | 1 | 2018–2018 |
| Robinson v. State green | 1 | 2017–2017 |
| Tornavacca v. State green | 1 | 2016–2016 |
| Kemp v. State green | 1 | 2016–2016 |
| Taffner v. Arkansas Department of Human Services green | 1 | 2016–2016 |
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.
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.