burden to overcome presumption (Florida) · Go Syfert
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burden to overcome presumption in Florida

23 Florida opinions name it 2 courts 2004–2022 1 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 (10)

CaseFollowedCited
Occhicone v. Stategreen
fla · 2000 · cited in 3 Florida opinions naming this issue, 2010–2014
2 sentences

2014Id. (quoting Michel v. Louisiana, 350 U.S. 91, 101 (1955)). “[S]trategic decisions do not constitute ineffective assistance of counsel if alternative courses have been considered and rejected and counsel’s decision was reasonable under the norms of professional conduct.” Occhicone v. State, 768 So. 2d 1037, 1048 (Fla. 2000).

2014Id. (quoting Michel v. Louisiana, 350 U.S. 91, 101 , 76 S.Ct. 158 , 100 L.Ed. 83 (1955)). “[Strategic decisions do not constitute ineffective assistance of counsel if alternative courses have been considered and rejected and counsel’s decision was reasonable under the norms of professional conduct.” Occhicone v. State, 768 So.2d 1037,1048 (Fla.2000).

33
Strickland v. Washingtongreen
scotus · 1984 · cited in 14 Florida opinions naming this issue, 2004–2014
2 sentences

2014“The defendant bears the burden to overcome the presumption that, under the circumstances, the challenged action might be considered sound trial strategy.” McCoy, 113 So.3d at 707 (quoting Strickland, 466 U.S. at 689 , 104 S.Ct. 2052 ).

2014“The defendant bears the burden to overcome the presumption that, under the circumstances, the challenged action might be considered sound trial strategy.” McCoy, 113 So. 3d at 707 (quoting Strickland, 466 U.S. at 689 ).

214
Wright v. Stategreen
fladistctapp · 2005 · cited in 2 Florida opinions naming this issue, 2011–2011
2 sentences

2011The statute does not, as Shelton implied, require the defendant to establish his innocence by proving a lack of knowledge, see Wright, 920 So.2d at 25 (explaining that section 893.101 “does not require the defendant to prove or disprove knowledge”); rather, the statute provides that if the defense is raised, the state has the burden to overcome the defense by proving beyond a reasonable doubt that the defendant knew of the illicit nature of the drugs.

2011The statute does not, as Shelton implied, require the defendant to establish his innocence by proving a lack of knowledge, see Wright, 920 So.2d at 25 (explaining that section 893.101 “does not require the defendant to prove or disprove knowledge”); rather, the statute provides that if the defense is raised, the state has the burden to overcome the defense by proving beyond a reasonable doubt that the defendant knew of the illicit nature of the drugs.

22
State v. Duncangreen
fla · 2004 · cited in 2 Florida opinions naming this issue, 2005–2006
2 sentences

2006See State v. Duncan, 894 So.2d 817, 823 (Fla.2004) (citing Strickland, 466 U.S. at 689 , 104 S.Ct. 2052 , and recognizing that "[t]he defendant alone carries the burden to overcome the presumption of effective assistance").

2005Maxwell v. Wainwright, 490 So.2d 927, 932 (Fla.1986). . . . [Furthermore] [t]he defendant alone carries the burden to overcome the presumption of effective assistance: "[T]he defendant must overcome the presumption that, under the circumstances, the challenged action `might be considered sound trial strategy.'" [ Strickland, 466 U.S. at 689-90 , 104 S.Ct. 2052 .] State v. Duncan, 894 So.2d 817, 823 (Fla. 2004), cert. denied, ___ U.S. ___, 126 S.Ct. 397 , 163 L.Ed.2d 275 (2005).

22
Michel v. Louisianagreen
scotus · 1956 · cited in 4 Florida opinions naming this issue, 2007–2014
2 sentences

2010“A fair assessment of attorney performance requires that every effort be made to eliminate the distorting effects of hindsight, to reconstruct the circumstances of counsel’s challenged conduct, and to evaluate the conduct from counsel’s perspective at the time.” Id. at 689 , 104 S.Ct. 2052 . *776 The defendant carries the burden to overcome the presumption that, under the circumstances, the challenged action “might be considered sound trial strategy.” Id. (quoting Michel v. Louisiana, 350 U.S. 91, 101 , 76 S.Ct. 158 , 100 L.Ed. 88 (1955)).

2010“A fair assessment of attorney performance requires that every effort be made to eliminate the distorting effects of hindsight, to reconstruct the circumstances of counsel’s challenged conduct, and to evaluate the conduct from counsel’s perspective at the time.” Id. at 689 , 104 S.Ct. 2052 . *776 The defendant carries the burden to overcome the presumption that, under the circumstances, the challenged action “might be considered sound trial strategy.” Id. (quoting Michel v. Louisiana, 350 U.S. 91, 101 , 76 S.Ct. 158 , 100 L.Ed. 88 (1955)).

14
Nelson v. Stategreen
fla · 2010 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018See Nelson v. State, 43 So. 3d 20, 28 (Fla. 2010) (“[T]he defendant carries the burden to overcome the presumption that, under the circumstances, the challenged action might be considered sound trial strategy.”). b.

11
State v. Adkinsgreen
fla · 2012 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013Id. at 430 (Pariente, J., concurring in result).

11
Pagan v. Stategreen
fla · 2009 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011See id.

11
Darling v. Stategreen
fla · 2007 · cited in 1 Florida opinions naming this issue, 2008–2008
1 sentence

2008See Darling, 966 So.2d at 382 ("The defendant carries the burden to overcome the presumption of effective assistance....") B.

11
Maxwell v. Wainwrightgreen
fla · 1986 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005Maxwell v. Wainwright, 490 So.2d 927, 932 (Fla.1986). . . . [Furthermore] [t]he defendant alone carries the burden to overcome the presumption of effective assistance: "[T]he defendant must overcome the presumption that, under the circumstances, the challenged action `might be considered sound trial strategy.'" [ Strickland, 466 U.S. at 689-90 , 104 S.Ct. 2052 .] State v. Duncan, 894 So.2d 817, 823 (Fla. 2004), cert. denied, ___ U.S. ___, 126 S.Ct. 397 , 163 L.Ed.2d 275 (2005).

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 (6)

CaseCitedYears
Celotex Corp. v. Catrett, Administratrix of the Estate of Catrett green
scotus · 1986
1 sentence

2022Id.; Celotex Corp., 477 U.S. at 322-24 ; Fla. R.

12022–2022
Tallahassee Housing v. Unemp. Appeals Com'n green
fla · 1986
1 sentence

2012Id.

12012–2012
Ring v. Arizona green
scotus · 2002
2 sentences

2008Petition for Writ of Habeas Corpus Jones presents three claims for habeas corpus relief, arguing that: (1) Florida's capital sentencing scheme is unconstitutional under Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002); (2) section 921.141, Florida Statutes and the standard penalty phase jury instructions improperly shifted the burden of proof to Jones to prove that death was inappropriate; and (3) the standard penalty phase jury instructions dilute the jury's responsibility by labeling their verdict as advisory and not binding.

2008Petition for Writ of Habeas Corpus Jones presents three claims for habeas corpus relief, arguing that: (1) Florida's capital sentencing scheme is unconstitutional under Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002); (2) section 921.141, Florida Statutes and the standard penalty phase jury instructions improperly shifted the burden of proof to Jones to prove that death was inappropriate; and (3) the standard penalty phase jury instructions dilute the jury's responsibility by labeling their verdict as advisory and not binding.

12008–2008
Emmer v. Brucato green
fladistctapp · 2002
1 sentence

2006Id.

12006–2006
Sherwood Partners, Inc. v. Lycos, Inc. green
ca9 · 2005
1 sentence

2005Maxwell v. Wainwright, 490 So.2d 927, 932 (Fla.1986). . . . [Furthermore] [t]he defendant alone carries the burden to overcome the presumption of effective assistance: "[T]he defendant must overcome the presumption that, under the circumstances, the challenged action `might be considered sound trial strategy.'" [ Strickland, 466 U.S. at 689-90 , 104 S.Ct. 2052 .] State v. Duncan, 894 So.2d 817, 823 (Fla. 2004), cert. denied, ___ U.S. ___, 126 S.Ct. 397 , 163 L.Ed.2d 275 (2005).

12005–2005
Globe Newspaper Co. v. Ayash green
scotus · 2005
1 sentence

2005Maxwell v. Wainwright, 490 So.2d 927, 932 (Fla.1986). . . . [Furthermore] [t]he defendant alone carries the burden to overcome the presumption of effective assistance: "[T]he defendant must overcome the presumption that, under the circumstances, the challenged action `might be considered sound trial strategy.'" [ Strickland, 466 U.S. at 689-90 , 104 S.Ct. 2052 .] State v. Duncan, 894 So.2d 817, 823 (Fla. 2004), cert. denied, ___ U.S. ___, 126 S.Ct. 397 , 163 L.Ed.2d 275 (2005).

12005–2005

Statutes the citing opinions construe

FL § 921.141 (6) FL § 893.101 (3) FL § 893.13 (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 103 (1989–2026) CA 32 (2014–2026) IL 31 (1977–2026) MO 26 (1981–2023) FL 23 (2004–2022) IN 14 (1973–2024) MS 14 (1996–2018) WI 13 (2006–2025) SD 12 (1996–2020) OH 9 (1978–2025) PA 9 (2010–2026) IA 8 (1941–2019) MI 8 (1975–2025) AL 7 (1912–2026) MT 7 (2011–2023) GA 6 (1972–2021) OR 6 (1985–2024) WA 6 (2016–2025) CT 5 (1985–2007) NM 5 (1975–2024) MN 5 (1920–2019) NJ 5 (1993–2016) ND 5 (1985–2015) MD 5 (1959–2022) NC 4 (1969–2026) ME 3 (1994–2023) LA 3 (1965–1997) NY 3 (1997–2026) AR 2 (2006–2006) SC 2 (2003–2005) TN 2 (2002–2007) VA 2 (2001–2018) KY 2 (1996–2021) KS 2 (2018–2020) VT 2 (2015–2026)

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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