lesser standard (Tennessee) · Go Syfert
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lesser standard in Tennessee

21 Tennessee opinions name it 3 courts 1989–2026 1 in the last five years

The cases below were cited by Tennessee 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 (17)

CaseFollowedCited
United States v. Jeffrey Scott Amosgreen
ca8 · 1986 · cited in 2 Tennessee opinions naming this issue, 1999–2010
2 sentences

2010"It is axiomatic, therefore, that a lesser standard of proof, such as the clear and convincing standard, may be imposed." United States v. Amos, 803 F.2d 419, 421 (8th Cir. 1986); see also United States v. Freeman, 804 F.2d 1574 (11th Cir. 1986).

1999Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952). *741 “It is axiomatic, therefore, that a lesser standard of proof, such as the clear and convincing standard, may be imposed.” United States v. Amos, 803 F.2d 419, 421 (8th Cir.1986).

22
Patterson v. New Yorkgreen
scotus · 1977 · cited in 2 Tennessee opinions naming this issue, 2002–2004
2 sentences

2004See, e.g., Patterson v. New York, 432 U.S. 197, 206-07 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977).

2004See, e.g., Patterson v. New York, 432 U.S. 197, 206-07 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977).

22
State v. Workmangreen
tenncrimapp · 2002 · cited in 3 Tennessee opinions naming this issue, 2005–2026
2 sentences

2026Furthermore, a lesser standard would appear to be more appropriate. . . . 111 S.W.3d at 18 .

2005Furthermore, a lesser standard would appear to be more appropriate . . . . -12- 111 S.W.3d at 18 .

13
Terry v. Ohiogreen
scotus · 1968 · cited in 1 Tennessee opinions naming this issue, 2018–2018
2 sentences

2018See Terry v. Ohio, 392 U.S. 1, 20-21 , 88 S. Ct. 1868, 1879-80 (1968).

2018See Terry v. Ohio, 392 U.S. 1, 20-21 , 88 S. Ct. 1868, 1879-80 (1968).

11
United States v. Dwayne Freemangreen
ca11 · 1986 · cited in 1 Tennessee opinions naming this issue, 2010–2010
1 sentence

2010"It is axiomatic, therefore, that a lesser standard of proof, such as the clear and convincing standard, may be imposed." United States v. Amos, 803 F.2d 419, 421 (8th Cir. 1986); see also United States v. Freeman, 804 F.2d 1574 (11th Cir. 1986).

11
Cooper v. Oklahomagreen
scotus · 1996 · cited in 1 Tennessee opinions naming this issue, 2002–2002
2 sentences

2002It is axiomatic, therefore, that a lesser standard of proof, such as the clear and convincing standard, may be imposed.”); cf. Cooper v. Oklahoma, 517 U.S. 348, 367-368 , 116 S. Ct. 1373, 1383 (1996). 4 Appellant’s issue IV. -23- Following Leland, the Court has clarified that placing the burden of proving an affirmative defense upon a criminal defendant will only violate due process if proving the affirmative defense necessarily negates any essential element of the offense.

2002It is axiomatic, therefore, that a lesser standard of proof, such as the clear and convincing standard, may be imposed.”); cf. Cooper v. Oklahoma, 517 U.S. 348, 367-368 , 116 S. Ct. 1373, 1383 (1996). 4 Appellant’s issue IV. -23- Following Leland, the Court has clarified that placing the burden of proving an affirmative defense upon a criminal defendant will only violate due process if proving the affirmative defense necessarily negates any essential element of the offense.

11
Michael L. Wood v. R.C. Marshall, Supt.green
ca6 · 1986 · cited in 1 Tennessee opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., Patterson v. New York, 432 U.S. 197, 206-207 , 97 S. Ct. 2319, 2325 (1977); Mullaney v. Wilbur, 421 U.S. 684, 686-687 , 95 S. Ct. 1881, 1883-1884 (1975); see also Gall v. Parker, 231 F.3d 265, 286-287 (6th Cir. 2000); Wood v. Marshall, 790 F.2d 548, 550 (6th Cir. 1986).

11
Mullaney v. Wilburgreen
scotus · 1975 · cited in 1 Tennessee opinions naming this issue, 2002–2002
2 sentences

2002See, e.g., Patterson v. New York, 432 U.S. 197, 206-207 , 97 S. Ct. 2319, 2325 (1977); Mullaney v. Wilbur, 421 U.S. 684, 686-687 , 95 S. Ct. 1881, 1883-1884 (1975); see also Gall v. Parker, 231 F.3d 265, 286-287 (6th Cir. 2000); Wood v. Marshall, 790 F.2d 548, 550 (6th Cir. 1986).

2002See, e.g., Patterson v. New York, 432 U.S. 197, 206-207 , 97 S. Ct. 2319, 2325 (1977); Mullaney v. Wilbur, 421 U.S. 684, 686-687 , 95 S. Ct. 1881, 1883-1884 (1975); see also Gall v. Parker, 231 F.3d 265, 286-287 (6th Cir. 2000); Wood v. Marshall, 790 F.2d 548, 550 (6th Cir. 1986).

11
Eugene Williams Gall, Jr. v. Phil Parker, Wardengreen
ca6 · 2000 · cited in 1 Tennessee opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., Patterson v. New York, 432 U.S. 197, 206-207 , 97 S. Ct. 2319, 2325 (1977); Mullaney v. Wilbur, 421 U.S. 684, 686-687 , 95 S. Ct. 1881, 1883-1884 (1975); see also Gall v. Parker, 231 F.3d 265, 286-287 (6th Cir. 2000); Wood v. Marshall, 790 F.2d 548, 550 (6th Cir. 1986).

11
State v. Johnsongreen
tenncrimapp · 1986 · cited in 1 Tennessee opinions naming this issue, 2002–2002
1 sentence

2002In Pruitt, our supreme court stated that a lesser standard would be tantamount to approval of “pure hearsay evidence of intoxication.” 393 S.W.2d at 752 ; see also State v. Johnson, 717 S.W.2d 298 (Tenn. Crim.

11
O'DANIEL v. Messiergreen
tennctapp · 1995 · cited in 1 Tennessee opinions naming this issue, 2001–2001
1 sentence

2001Although this is a higher standard than “preponderance of the evidence,” it is a lesser standard than “beyond a reasonable doubt.” O’Daniel v. Messier, 905 S.W.2d 182, 188 (Tenn. Ct. App. 1995).

11
State v. Turnergreen
tenncrimapp · 1995 · cited in 1 Tennessee opinions naming this issue, 2000–2000
1 sentence

2000Tennessee courts have determined that there has been “manifest injustice” where the guilty plea was entered as a result of “coercion, fraud, duress or mistake,” Capri Adult Cinema v. State, 537 S.W.2d 896, 898 (Tenn. 1976); “fear,” Swang v. State, 42 Tenn. (2 Cold.) 212 , 213-14 (1865); “gross misrepresentation” by the prosecution, id. at 214-15; or the plea was not voluntarily, understandingly, or knowingly entered, State v. Turner, 919 S.W.2d 346, 355 (Tenn. Crim.

11
State v. Burnsgreen
tenn · 1999 · cited in 1 Tennessee opinions naming this issue, 2000–2000
1 sentence

2000See State v. Burns, 6 S.W.3d 453, 466-67 (Tenn. 1999).

11
Capri Adult Cinema v. Stategreen
tenn · 1976 · cited in 1 Tennessee opinions naming this issue, 2000–2000
1 sentence

2000Tennessee courts have determined that there has been “manifest injustice” where the guilty plea was entered as a result of “coercion, fraud, duress or mistake,” Capri Adult Cinema v. State, 537 S.W.2d 896, 898 (Tenn. 1976); “fear,” Swang v. State, 42 Tenn. (2 Cold.) 212 , 213-14 (1865); “gross misrepresentation” by the prosecution, id. at 214-15; or the plea was not voluntarily, understandingly, or knowingly entered, State v. Turner, 919 S.W.2d 346, 355 (Tenn. Crim.

11
Swang v. Stategreen
tenn · 1865 · cited in 1 Tennessee opinions naming this issue, 2000–2000
2 sentences

2000Tennessee courts have determined that there has been “manifest injustice” where the guilty plea was entered as a result of “coercion, fraud, duress or mistake,” Capri Adult Cinema v. State, 537 S.W.2d 896, 898 (Tenn. 1976); “fear,” Swang v. State, 42 Tenn. (2 Cold.) 212 , 213-14 (1865); “gross misrepresentation” by the prosecution, id. at 214-15; or the plea was not voluntarily, understandingly, or knowingly entered, State v. Turner, 919 S.W.2d 346, 355 (Tenn. Crim.

2000Tennessee courts have determined that there has been “manifest injustice” where the guilty plea was entered as a result of “coercion, fraud, duress or mistake,” Capri Adult Cinema v. State, 537 S.W.2d 896, 898 (Tenn. 1976); “fear,” Swang v. State, 42 Tenn. (2 Cold.) 212 , 213-14 (1865); “gross misrepresentation” by the prosecution, id. at 214-15; or the plea was not voluntarily, understandingly, or knowingly entered, State v. Turner, 919 S.W.2d 346, 355 (Tenn. Crim.

11
State v. Swindlegreen
tenn · 2000 · cited in 1 Tennessee opinions naming this issue, 2000–2000
1 sentence

2000This is true whether the standard is “harmless beyond a reasonable doubt” or under the lesser standard that the error “more probably than not affected the judgment to the defendant’s prejudice.” See State v. Swindle, 30 S.W.3d 289, 293 (Tenn. 2000); State v. Williams, 977 S.W.2d 101, 105 (Tenn. 1998) Regarding the Defendant’s assertion that the trial court erred in failing to charge “joyriding,” i.e. unauthorized use of a vehicle as prohibited in Tennessee Code Annotated section 39-14-106, we note that this court has previously held that “joyriding” is a lesser-included offense of theft of a v

11
State v. Williamsgreen
tenn · 1998 · cited in 1 Tennessee opinions naming this issue, 2000–2000
1 sentence

2000This is true whether the standard is “harmless beyond a reasonable doubt” or under the lesser standard that the error “more probably than not affected the judgment to the defendant’s prejudice.” See State v. Swindle, 30 S.W.3d 289, 293 (Tenn. 2000); State v. Williams, 977 S.W.2d 101, 105 (Tenn. 1998) Regarding the Defendant’s assertion that the trial court erred in failing to charge “joyriding,” i.e. unauthorized use of a vehicle as prohibited in Tennessee Code Annotated section 39-14-106, we note that this court has previously held that “joyriding” is a lesser-included offense of theft of a v

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
In Re Swanson green
tenn · 1999
2 sentences

2016The issue is whether placing [the child] in the custody of [father] would pose substantial harm to her physical or psychological welfare.” The Supreme Court “reject[s] the contention . . . that at some point the fact that the child has been in the custody of a non-parent for a period of time means that a lesser standard can be applied in determining whether parental rights may be terminated.” In re Swanson, 2 S.W.3d 180 , 188 n.13 (Tenn. 1999).

2016In re Swanson, 2 S.W.3d at 188 n. - 15 - 13.

32007–2016
Catholic Ldrship Coaltn of TX v. David Reis green
ca5 · 2014
1 sentence

2019Catholic Leadership Coal. of Texas, 764 F.3d. at 427 .

12019–2019
State v. Turner green
tenn · 2009
2 sentences

2018Turner, 297 S.W.3d at 162 n.4. “[T]he Court left open the question ‘whether. . . a search by a law enforcement officer without any individualized suspicion would have satisfied the reasonableness requirement of the Fourth Amendment.’” Id. at 162 .

2018Turner, 297 S.W.3d at 162 n.4. “[T]he Court left open the question ‘whether. . . a search by a law enforcement officer without any individualized suspicion would have satisfied the reasonableness requirement of the Fourth Amendment.’” Id. at 162 .

12018–2018
In Re CWW green
tennctapp · 2000
1 sentence

2008Id.

12008–2008
State v. Hall green
tenn · 1998
1 sentence

2008Id. app. at 170-71.

12008–2008
Pruitt v. State green
tenn · 1965
1 sentence

2002In Pruitt, our supreme court stated that a lesser standard would be tantamount to approval of “pure hearsay evidence of intoxication.” 393 S.W.2d at 752 ; see also State v. Johnson, 717 S.W.2d 298 (Tenn. Crim.

12002–2002
Leland v. Oregon green
scotus · 1952
2 sentences

1999Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952). *741 “It is axiomatic, therefore, that a lesser standard of proof, such as the clear and convincing standard, may be imposed.” United States v. Amos, 803 F.2d 419, 421 (8th Cir.1986).

1999Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952). *741 “It is axiomatic, therefore, that a lesser standard of proof, such as the clear and convincing standard, may be imposed.” United States v. Amos, 803 F.2d 419, 421 (8th Cir.1986).

11999–1999
Sullivan v. Louisiana green
scotus · 1993
2 sentences

1997Sullivan, 508 U.S. at 280 , 113 S.Ct. at 2080-2082 .

1997Sullivan, 508 U.S. at 280 , 113 S.Ct. at 2080-2082 .

11997–1997
United States v. Pablo Berrios green
ca2 · 1974
1 sentence

1997United States v. Berrios, 501 F.2d at 1211-12 .

11997–1997
Adams v. Williams green
scotus · 1972
2 sentences

1989Adams, 407 U.S. at 145 , 92 S.Ct. at 1923 .

1989Adams, 407 U.S. at 145 , 92 S.Ct. at 1923 .

11989–1989

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 39-11-501 (5) TN § Tenn. Code Ann. § 36-1-113 (3) TN § Tenn. Code Ann. § 39-11-201 (3) TN § Tenn. Code Ann. § 39-13-202 (3) TN § Tenn. Code Ann. § 39-13-204 (3) TN § Tenn. Code Ann. § 39-13-206 (3) TN § Tenn. Code Ann. § 39-17-417 (3) TN § Tenn. Code Ann. § 40-26-105 (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

CA 182 (1906–2026) TX 127 (1970–2026) OH 118 (1973–2025) NY 114 (1933–2026) IL 112 (1962–2025) PA 101 (1974–2026) IN 75 (1974–2026) LA 70 (1967–2025) FL 69 (1974–2025) WA 55 (1980–2026) CT 51 (1976–2024) MI 48 (1979–2026) GA 42 (1924–2023) NJ 41 (1953–2026) MD 41 (1975–2026) DC 34 (1970–2024) MA 33 (1966–2025) VA 31 (1982–2024) AZ 29 (1977–2026) KS 27 (1977–2026) AL 22 (1979–2024) TN 21 (1989–2026) OR 20 (1969–2023) CO 19 (1979–2026) WI 18 (1925–2023) NM 17 (1975–2017) MN 17 (1980–2014) OK 17 (1962–2022) MO 16 (1987–2020) MS 16 (1987–2025) IA 15 (1974–2022) NC 14 (1958–2026) KY 13 (1964–2024) AR 12 (1983–2023) ID 12 (1980–2014) WV 12 (1979–2022) AK 12 (1977–2017) VT 12 (1975–2020) MT 11 (2005–2026) RI 11 (1983–2011) SC 10 (1989–2020) NE 10 (1982–2023) UT 9 (1929–2024) DE 9 (1973–2026) ND 9 (1990–2016) WY 9 (1990–2022) SD 6 (1979–2008) ME 6 (1981–2018) NH 6 (1980–2019) HI 5 (1984–2007) NV 5 (1997–2022)

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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