ineffective assistance of counsel claim (Alabama) · Go Syfert
← Alabama issues

ineffective assistance of counsel claim in Alabama

131 Alabama opinions name it 3 courts 1985–2026 9 in the last five years

The cases below were cited by Alabama 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 (46)

CaseFollowedCited
Strickland v. Washingtongreen
scotus · 1984 · cited in 67 Alabama opinions naming this issue, 1985–2024
2 sentences

2024Pursuant to Strickland v. Washington, 466 U.S. 668 (1984), a defendant who seeks relief on an ineffective-assistance-of-counsel claim must prove both that his counsel's performance was deficient and that he was prejudiced by the deficient performance.

2024Rather, the pertinent question is whether Williams and Sutton's performance was objectively reasonable, i.e., whether " 'some reasonable lawyer' could have pursued the challenged course of conduct," Gissendanner v. Seaboldt, 735 F.3d 1311, 1323 (11th Cir. 2013) (citation omitted), and, as I have explained, and as Burger, Allen, and Reed demonstrate, the answer to that question is "yes." To prevail on an ineffective-assistance-of-counsel claim, a defendant must demonstrate that his counsel committed "errors so serious that [they] were not functioning as the 'counsel' guaranteed by the Sixth Ame

1467
McNair v. Stategreen
alacrimapp · 1997 · cited in 12 Alabama opinions naming this issue, 1999–2017
2 sentences

2017Ex parte Baldwin , 456 So.2d 129 (Ala. 1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." 706 So.2d at 839 .

2006As this Court noted in McNair v. State , 706 So.2d 828 , 839 (Ala.Crim.App. 1997): "In order to prevail on an ineffective assistance of counsel claim, a defendant must meet the two-pronged test set out by Strickland v. Washington , 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984). "`First, the defendant must show that counsel's performance was deficient.

512
Boyd v. Stategreen
alacrimapp · 1999 · cited in 3 Alabama opinions naming this issue, 2004–2013
2 sentences

2013Boyd v. State, 746 So.2d 364, 882 (Ala.Crim.App.1999).

2011See Boyd v. State, 746 So.2d 364, 406 (Ala.Crim.App.1999) (holding that ‘Rule 32.6(b) requires that the petition itself disclose the facts relied upon in seeking relief) ... see also Coral v. State, [ 900 So.2d 1274 (Ala.Crim.App.2004) ] (holding that ‘[e]ach subcategory [of an ineffective assistance of counsel claim] is an independent claim that must be sufficiently pleaded.’).” *32 (Supp.

33
Ex Parte EDgreen
ala · 2000 · cited in 3 Alabama opinions naming this issue, 2000–2003
2 sentences

2003See Ex parte E.D., 777 So.2d 113 (Ala.2000).

2003See Ex parte E.D., 777 So.2d 113 (Ala.2000).

33
Ex Parte Ingramgreen
ala · 1996 · cited in 9 Alabama opinions naming this issue, 1996–2008
2 sentences

2002Rule 32.7(d), Ala.R.Crim.P., provides for the summary disposition of a Rule 32 petition only "[i]f the court determines that the petition is not sufficiently specific [in violation of Rule 32.6(b)], or is precluded [under Rule 32.2, Ala.R.Crim.P.], or fails to state a claim, or that no material issue of fact or law exists which would entitle the petitioner to relief under this rule and that no purpose would be served by any further proceedings. . . ." Although not precluded by Rule 32.2(a)(5), Ala.R.Crim.P., see Ex parte Ingram , 675 So.2d 863 (Ala. 1996), 2 the *Page 859 circuit court's summa

2001Ex parte Ingram , 675 So.2d 863 , 866 (Ala. 1996) ("When a defendant makes a claim of ineffective assistance of trial counsel, and that claim cannot reasonably be presented in a new trial motion filed within the 30 days allowed by Rule 24.1(b), Ala.R.Crim.P., the proper method for presenting that claim for appellate review is to file a Rule 32, Ala.R.Crim.P., petition for post-conviction relief.") Thus it was the ineffective-assistance-of-counsel claim that concerned the Court in Hamlett .

29
Hunt v. Stategreen
alacrimapp · 2005 · cited in 6 Alabama opinions naming this issue, 2005–2017
2 sentences

2017App. 2015) (quoting Brown v. State , 288 Ga. 902 , 909, 708 S.E.2d 294 , 301 (2011) ). " 'Trial counsel's decisions regarding what theory of the case to pursue represent the epitome of trial strategy.' Flowers v. State , 2010 Ark. 364 , 370 S.W.3d 228 , 232 (2010). 'What defense to carry to the jury, what witnesses to call, and what method of presentation to use is the epitome of a strategic decision, and it is one that we will seldom, if ever, second guess.' State v. Miller , 194 W.Va. 3 , 16, 459 S.E.2d 114 , 127 (1995). " ' " '[T]he mere existence of a potential alternative defense theory i

2005As I stated in Hunt v. State, 940 So.2d 1041, 1073 (Ala.Crim.App. 2005)(Cobb, J., concurring in part and dissenting in part), and in my special writings in the cases cited therein, neither Alabama law nor due process allows for the preclusion of a finding of prejudice with regard to an ineffective-assistance-of-counsel claim solely because this Court or the Alabama Supreme Court examined the underlying substantive issue on direct appeal and found no plain error.

26
Brown v. Stategreen
ga · 2011 · cited in 4 Alabama opinions naming this issue, 2017–2023
2 sentences

2023Id. '[S]trategic choices made after a thorough investigation of the law and the facts relevant to plausible opinions are virtually unchallengeable.' Anderson [v. State], 196 S.W.3d [28] at 33 [(Mo. 2006)] (quoting Strickland, 466 U.S. at 690 , 104 S.Ct. 2052 )." McLaughlin v. State, 378 S.W.3d 328, 337 (Mo. 2012). "[A] tactical decision will not form the basis for an ineffective assistance of counsel claim unless it was 'so patently unreasonable that no competent attorney would have chosen it.' " Brown v. State, 288 Ga. 902, 909 , 708 S.E.2d 294, 301 (2011).

2023Id. '[S]trategic choices made after a thorough investigation of the law and the facts relevant to plausible opinions are virtually unchallengeable.' Anderson [v. State], 196 S.W.3d [28] at 33 [(Mo. 2006)] (quoting Strickland, 466 U.S. at 690 , 104 S.Ct. 2052 )." McLaughlin v. State, 378 S.W.3d 328, 337 (Mo. 2012). "[A] tactical decision will not form the basis for an ineffective assistance of counsel claim unless it was 'so patently unreasonable that no competent attorney would have chosen it.' " Brown v. State, 288 Ga. 902, 909 , 708 S.E.2d 294, 301 (2011).

24
Coral v. Stategreen
alacrimapp · 2004 · cited in 4 Alabama opinions naming this issue, 2009–2016
2 sentences

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

24
Cogman v. Stategreen
alacrimapp · 2002 · cited in 3 Alabama opinions naming this issue, 2006–2015
2 sentences

2015P., see, e.g., Cogman v. State, 852 So.2d 191, 192 (Ala.Crim.App.2002) (“An ineffective assistance of counsel claim is not jurisdictional; therefore, it is subject to the limitations period in Rule 32.2(c).”); that Hurst’s petition was untimely filed; that the State alleged in its motion to dismiss that Hurst’s claim was time-barred under Rule 32.2(c); and that the circuit court granted Hurst an evidentiary hearing, which provided Hurst with an opportunity to prove his claims.

2015P. See Wallace v. State, 959 So.2d 1161, 1163-64 (Aa.Crim.App.2006) (holding that a claim that a guilty plea was involuntarily and unknowingly entered “based on the alleged failure by his trial counsel and the trial court to advise him of a number of rights” is a nonjurisdictional claim); and Cogman v. State, 852 So.2d 191, 192 (Aa.Crim.App.2002) (“An ineffective assistance of counsel claim is not jurisdictional; therefore, it is subject to the limitations period in Rule 32.2(c).”).

23
Thompson v. Stategreen
ala · 1985 · cited in 3 Alabama opinions naming this issue, 1993–1999
2 sentences

1999See Thomas v. State , 525 So.2d 816 (Ala.Cr.App. 1984), aff'd, 525 So.2d 820 (Ala. 1985), cert. denied, 488 U.S. 834 , 109 S.Ct. 94 , 102 L.Ed.2d 70 (1988) (remanding for an evidentiary hearing and specific findings of fact on the ineffective-assistance-of-counsel claim raised on direct appeal) (citing Ex parte Daniel , 459 So.2d 942 (Ala. 1982), aff'd, 459 So.2d 948 (Ala. 1984), cert. denied, 471 U.S. 1009 , 105 S.Ct. 1878 , 85 L.Ed.2d 170 (1985); and Delevie v. State , 454 So.2d 1044 (Ala.Cr.App. 1984)).

1995However, we have held that the Court of Criminal Appeals can remand a case for the trial court to hear an ineffective assistance of counsel claim, where the claim is first raised on appeal ‘if it determines justice would require it.’ Thompson v. State, 525 So.2d 820, 831 (Ala.1985) (emphasis in original).” We find that the appellant has attempted to raise the issue of trial counsel’s alleged ineffectiveness in connection with the absent juror both at trial and on appeal.

23
McNabb v. Stategreen
alacrimapp · 2007 · cited in 2 Alabama opinions naming this issue, 2016–2016
22
Knight v. Stategreen
alacrimapp · 1999 · cited in 2 Alabama opinions naming this issue, 2002–2004
22
Washington v. Stategreen
alacrimapp · 2012 · cited in 3 Alabama opinions naming this issue, 2025–2026
2 sentences

2026In short, "the allegedly omitted mitigation evidence would not have affected his decision that the aggravating circumstances outweighed the mitigating circumstances and mandated a death sentence." Washington, 95 So. 3d at 53.

2026In short, "the allegedly omitted mitigation evidence would not have affected his decision that the aggravating circumstances outweighed the mitigating circumstances and mandated a death sentence." Washington, 95 So. 3d at 53 .

13
Ex Parte Piercegreen
ala · 2000 · cited in 3 Alabama opinions naming this issue, 2017–2023
2 sentences

2023See Ex parte Pierce, 851 So. 2d 606, 614 (Ala. 2000) ("Rule 32.1(a) is the … provision that allows a defendant to raise an ineffective-assistance-of- counsel claim in a postconviction proceeding.").

2017App. 2013) (quoting Ex parte Pierce , 851 So.2d 606 , 614 (Ala. 2000) ).

13
Goodwin v. Johnsongreen
ca6 · 2011 · cited in 2 Alabama opinions naming this issue, 2013–2016
12
Everett v. Stategreen
nd · 2008 · cited in 2 Alabama opinions naming this issue, 2013–2016
12
Hughes v. Stategreen
nd · 2002 · cited in 2 Alabama opinions naming this issue, 2013–2016
12
Jalowiec v. Bradshawgreen
ca6 · 2011 · cited in 2 Alabama opinions naming this issue, 2013–2016
12
Jeffrey D. Hill v. Betty Mitchell, Wardengreen
ca6 · 2005 · cited in 2 Alabama opinions naming this issue, 2013–2016
12
Richard Nields v. Margaret Bradshaw, Wardengreen
ca6 · 2007 · cited in 2 Alabama opinions naming this issue, 2013–2016
12
Brown v. Stategreen
alacrimapp · 1995 · cited in 2 Alabama opinions naming this issue, 2000–2014
12
Carl Puiatti v. Secretary, Florida Department of Correctionsgreen
ca11 · 2013 · cited in 1 Alabama opinions naming this issue, 2024–2024
11
John Mills, Jr. v. Harry K. Singletary, Secretary, Florida Department of Correctionsgreen
ca11 · 1995 · cited in 1 Alabama opinions naming this issue, 2024–2024
11
Harrington v. Richtergreen
scotus · 2011 · cited in 1 Alabama opinions naming this issue, 2024–2024
11
Kelly Renee Gissendaner v. Kathy Seaboldt, Warden, Metro State Prisongreen
ca11 · 2013 · cited in 1 Alabama opinions naming this issue, 2024–2024
11
McWhorter v. Stategreen
alacrimapp · 2011 · cited in 1 Alabama opinions naming this issue, 2024–2024
11
United States v. Brian Connergreen
ca4 · 2011 · cited in 1 Alabama opinions naming this issue, 2023–2023
11
McLaughlin v. Stategreen
mo · 2012 · cited in 1 Alabama opinions naming this issue, 2023–2023
11
Bearden v. Stategreen
alacrimapp · 2001 · cited in 1 Alabama opinions naming this issue, 2023–2023
11
Ex Parte Lawleygreen
ala · 1987 · cited in 1 Alabama opinions naming this issue, 2023–2023
11
McKenzie v. Stategreen
ga · 2008 · cited in 1 Alabama opinions naming this issue, 2022–2022
11
Benjamin v. Stategreen
alacrimapp · 2013 · cited in 1 Alabama opinions naming this issue, 2022–2022
11
Ex Parte Boatwrightgreen
ala · 1985 · cited in 1 Alabama opinions naming this issue, 2017–2017
11
White v. Stategreen
alacrimapp · 2011 · cited in 1 Alabama opinions naming this issue, 2016–2016
11
Wallace v. Stategreen
alacrimapp · 2006 · cited in 1 Alabama opinions naming this issue, 2015–2015
11
Jones v. Stategreen
alacrimapp · 2005 · cited in 1 Alabama opinions naming this issue, 2015–2015
11
Commonwealth v. Smithgreen
pa · 2011 · cited in 1 Alabama opinions naming this issue, 2013–2013
11
Commonwealth v. Uderragreen
pa · 2004 · cited in 1 Alabama opinions naming this issue, 2013–2013
11
Davidson v. Genglergreen
wiwd · 1994 · cited in 1 Alabama opinions naming this issue, 2013–2013
11
Phillip Alexander Atkins v. Harry K. Singletarygreen
ca11 · 1992 · cited in 1 Alabama opinions naming this issue, 2013–2013
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (34)

CaseCitedYears
Ex Parte Baldwin green
ala · 1984
2 sentences

2023Ex parte Baldwin, 456 So. 2d 129 (Ala. 1984), aff'd, 472 U.S. 372 , 105 S. Ct. 2727 , 86 L.

2006Ex parte Baldwin , 456 So.2d 129 (Ala. 1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." Here, Shaw has failed to meet the two-pronged test required by Strickland to prevail on an ineffective-assistance-of-counsel claim.

151997–2023
Baldwin v. Alabama green
scotus · 1985
2 sentences

2006Ex parte Baldwin , 456 So.2d 129 (Ala. 1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." Here, Shaw has failed to meet the two-pronged test required by Strickland to prevail on an ineffective-assistance-of-counsel claim.

2006Ex parte Baldwin , 456 So.2d 129 (Ala. 1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." Here, Shaw has failed to meet the two-pronged test required by Strickland to prevail on an ineffective-assistance-of-counsel claim.

151997–2023
Nwosun v. General Mills Restaurants, Inc. green
scotus · 1998
2 sentences

2000Ex parte Baldwin, 456 So.2d 129 (Ala.1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." McNair v. State, 706 So.2d 828, 839 (Ala. Cr.App.1997), cert. denied, 523 U.S. 1064 , 118 S.Ct. 1396 , 140 L.Ed.2d 654 (1998).

2000Ex parte Baldwin, 456 So.2d 129 (Ala.1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." McNair v. State, 706 So.2d 828, 839 (Ala. Cr.App.1997), cert. denied, 523 U.S. 1064 , 118 S.Ct. 1396 , 140 L.Ed.2d 654 (1998).

51999–2000
Hoskinson v. Indiana green
scotus · 1998
2 sentences

2000Ex parte Baldwin, 456 So.2d 129 (Ala.1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." McNair v. State, 706 So.2d 828, 839 (Ala. Cr.App.1997), cert. denied, 523 U.S. 1064 , 118 S.Ct. 1396 , 140 L.Ed.2d 654 (1998).

2000Ex parte Baldwin, 456 So.2d 129 (Ala.1984), aff'd, 472 U.S. 372 , 105 S.Ct. 2727 , 86 L.Ed.2d 300 (1985)." McNair v. State, 706 So.2d 828, 839 (Ala. Crim.App.1997), cert. denied, 523 U.S. 1064 , 118 S.Ct. 1396 , 140 L.Ed.2d 654 (1998).

51999–2000
Partain v. State green
alacrimapp · 2008
2 sentences

2026Id. (citing Ex parte Walker, 800 So. 2d 135 (Ala. 2000)).

2026Id. (citing Ex parte Walker, 800 So. 2d 135 (Ala. 2000)).

32025–2026
Ex Parte Walker green
ala · 2000
2 sentences

2026Id. (citing Ex parte Walker, 800 So. 2d 135 (Ala. 2000)).

2026Id. (citing Ex parte Walker, 800 So. 2d 135 (Ala. 2000)).

32025–2026
Ex Parte Jenkins green
ala · 2005
2 sentences

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

32009–2016
Ex Parte MacEwan green
ala · 2002
2 sentences

2007Therefore, in order to allow the trial court to properly inquire into the merits of MacEwan's ineffective-assistance-of-counsel claim, we reverse the judgment of the Court of Criminal Appeals and remand the case for that court to remand it for the trial court to hold an evidentiary hearing." 860 So.2d at 897 .

2006Therefore, in order to allow the trial court to properly inquire into the merits of MacEwan's ineffective-assistance-of-counsel claim, we reverse the judgment of the Court of Criminal Appeals and remand the case for that court to remand it for the trial court to hold an evidentiary hearing." 860 So.2d at 897 -98 .

32002–2007
Williams v. State green
alacrimapp · 1985
2 sentences

2003Williams v. State, 480 So.2d 1265 (Ala.Crim.App.1985).

2002Williams v. State, 480 So.2d 1265 (Ala.Crim.App.1985).

32001–2003
Occhicone v. State green
fla · 2000
2 sentences

2017App. 2016) (quoting Occhicone v. State , 768 So.2d 1037 , 1048 (Fla. 2000) ). " '[A] tactical decision will not form the basis for an ineffective assistance of counsel claim unless it was "so patently unreasonable that no competent attorney would have chosen it." ' " State v. Gissendanner , [Ms. CR-09-0998, October 23, 2015] --- So.3d ----, ---- (Ala. Crim.

2017App. 2016) (quoting Occhicone v. State , 768 So.2d 1037 , 1048 (Fla. 2000) ). " '[A] tactical decision will not form the basis for an ineffective assistance of counsel claim unless it was "so patently unreasonable that no competent attorney would have chosen it." ' " State v. Gissendanner , [Ms. CR-09-0998, October 23, 2015] --- So.3d ----, ---- (Ala. Crim.

22017–2017
Flowers v. State green
ark · 2010
2 sentences

2017App. 2015) (quoting Brown v. State , 288 Ga. 902 , 909, 708 S.E.2d 294 , 301 (2011) ). " 'Trial counsel's decisions regarding what theory of the case to pursue represent the epitome of trial strategy.' Flowers v. State , 2010 Ark. 364 , 370 S.W.3d 228 , 232 (2010). 'What defense to carry to the jury, what witnesses to call, and what method of presentation to use is the epitome of a strategic decision, and it is one that we will seldom, if ever, second guess.' State v. Miller , 194 W.Va. 3 , 16, 459 S.E.2d 114 , 127 (1995). " ' " '[T]he mere existence of a potential alternative defense theory i

2017App. 2015) (quoting Brown v. State , 288 Ga. 902 , 909, 708 S.E.2d 294 , 301 (2011) ). " 'Trial counsel's decisions regarding what theory of the case to pursue represent the epitome of trial strategy.' Flowers v. State , 2010 Ark. 364 , 370 S.W.3d 228 , 232 (2010). 'What defense to carry to the jury, what witnesses to call, and what method of presentation to use is the epitome of a strategic decision, and it is one that we will seldom, if ever, second guess.' State v. Miller , 194 W.Va. 3 , 16, 459 S.E.2d 114 , 127 (1995). " ' " '[T]he mere existence of a potential alternative defense theory i

22017–2017
State v. Miller green
wva · 1995
2 sentences

2017App. 2015) (quoting Brown v. State , 288 Ga. 902 , 909, 708 S.E.2d 294 , 301 (2011) ). " 'Trial counsel's decisions regarding what theory of the case to pursue represent the epitome of trial strategy.' Flowers v. State , 2010 Ark. 364 , 370 S.W.3d 228 , 232 (2010). 'What defense to carry to the jury, what witnesses to call, and what method of presentation to use is the epitome of a strategic decision, and it is one that we will seldom, if ever, second guess.' State v. Miller , 194 W.Va. 3 , 16, 459 S.E.2d 114 , 127 (1995). " ' " '[T]he mere existence of a potential alternative defense theory i

2017App. 2015) (quoting Brown v. State , 288 Ga. 902 , 909, 708 S.E.2d 294 , 301 (2011) ). " 'Trial counsel's decisions regarding what theory of the case to pursue represent the epitome of trial strategy.' Flowers v. State , 2010 Ark. 364 , 370 S.W.3d 228 , 232 (2010). 'What defense to carry to the jury, what witnesses to call, and what method of presentation to use is the epitome of a strategic decision, and it is one that we will seldom, if ever, second guess.' State v. Miller , 194 W.Va. 3 , 16, 459 S.E.2d 114 , 127 (1995). " ' " '[T]he mere existence of a potential alternative defense theory i

22017–2017
Stallworth v. State green
alacrimapp · 2013
2 sentences

2017As a constitutional claim, " ' Rule 32.1(a) is the ... provision that allows a defendant to raise an ineffective-assistance-of-counsel claim in a postconviction proceeding.' " Stallworth v. State , 171 So.3d 53 , 76 (Ala. Crim.

2017As a constitutional claim, " ' Rule 32.1(a) is the ... provision that allows a defendant to raise an ineffective-assistance-of-counsel claim in a postconviction proceeding.' " Stallworth v. State , 171 So.3d 53 , 76 (Ala. Crim.

22017–2017
Williams v. Taylor green
scotus · 2000
2 sentences

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

22016–2016
Boyd v. State green
alacrimapp · 2003
22016–2016
McNeil v. District of Columbia Department of Employment Services green
scotus · 2005
2 sentences

2016Ct. App. 2002). 'A petitioner's failure to "show how, but for the attorneys' errors, the results of the proceedings would have been different" justifies a district court's decision to summarily dismiss the ineffective assistance of counsel claim.' Everett v. State , 757 N.W.2d 530 , 535 (N.D. 2008) (quoting Hughes v. State , 639 N.W.2d 696 , 699 (N.D. 2002) ). '[F]ailing to introduce additional mitigation evidence that is only cumulative of that already presented does not amount to ineffective assistance.' Jalowiec v. Bradshaw , 657 F.3d 293 , 319 (6th Cir. 2011) (citing Nields v. Bradshaw , 4

2013“A petitioner’s failure to ‘show how, but for the attorneys’ errors, the results of the proceedings would have been different’ justifies a district court’s decision to summarily dismiss the ineffective assistance of counsel claim.” Everett v. State, 757 N.W.2d 530, 535 (N.D.2008) (quoting Hughes v. State, 639 N.W.2d 696, 699 (N.D.2002)). “[F]ailing to introduce additional mitigation evidence that is only cumulative of that already presented does not amount to ineffective assistance.” Jalowiec v. Bradshaw, 657 F.3d 293, 319 (6th Cir.2011) (citing Nields v. Bradshaw, 482 F.3d 442, 454 (6th Cir.2

22013–2016
Thai v. Mapes green
scotus · 2005
2 sentences

2016Ct. App. 2002). 'A petitioner's failure to "show how, but for the attorneys' errors, the results of the proceedings would have been different" justifies a district court's decision to summarily dismiss the ineffective assistance of counsel claim.' Everett v. State , 757 N.W.2d 530 , 535 (N.D. 2008) (quoting Hughes v. State , 639 N.W.2d 696 , 699 (N.D. 2002) ). '[F]ailing to introduce additional mitigation evidence that is only cumulative of that already presented does not amount to ineffective assistance.' Jalowiec v. Bradshaw , 657 F.3d 293 , 319 (6th Cir. 2011) (citing Nields v. Bradshaw , 4

2013“A petitioner’s failure to ‘show how, but for the attorneys’ errors, the results of the proceedings would have been different’ justifies a district court’s decision to summarily dismiss the ineffective assistance of counsel claim.” Everett v. State, 757 N.W.2d 530, 535 (N.D.2008) (quoting Hughes v. State, 639 N.W.2d 696, 699 (N.D.2002)). “[F]ailing to introduce additional mitigation evidence that is only cumulative of that already presented does not amount to ineffective assistance.” Jalowiec v. Bradshaw, 657 F.3d 293, 319 (6th Cir.2011) (citing Nields v. Bradshaw, 482 F.3d 442, 454 (6th Cir.2

22013–2016
Hill v. Mitchell green
scotus · 2005
2 sentences

2016Ct. App. 2002). 'A petitioner's failure to "show how, but for the attorneys' errors, the results of the proceedings would have been different" justifies a district court's decision to summarily dismiss the ineffective assistance of counsel claim.' Everett v. State , 757 N.W.2d 530 , 535 (N.D. 2008) (quoting Hughes v. State , 639 N.W.2d 696 , 699 (N.D. 2002) ). '[F]ailing to introduce additional mitigation evidence that is only cumulative of that already presented does not amount to ineffective assistance.' Jalowiec v. Bradshaw , 657 F.3d 293 , 319 (6th Cir. 2011) (citing Nields v. Bradshaw , 4

2013“A petitioner’s failure to ‘show how, but for the attorneys’ errors, the results of the proceedings would have been different’ justifies a district court’s decision to summarily dismiss the ineffective assistance of counsel claim.” Everett v. State, 757 N.W.2d 530, 535 (N.D.2008) (quoting Hughes v. State, 639 N.W.2d 696, 699 (N.D.2002)). “[F]ailing to introduce additional mitigation evidence that is only cumulative of that already presented does not amount to ineffective assistance.” Jalowiec v. Bradshaw, 657 F.3d 293, 319 (6th Cir.2011) (citing Nields v. Bradshaw, 482 F.3d 442, 454 (6th Cir.2

22013–2016
Brooks v. State green
alacrimapp · 2005
22016–2016
Jarrod Taylor v. State of Alabama. green
alacrimapp · 2010
22016–2016
Bryant v. State green
alacrimapp · 2011
2 sentences

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

2016For example, in Bryant v. State , 181 So.3d 1087 , 1104 (Ala.Crim.App.2011), we stated that "it is well settled in Alabama that an ineffective-assistance-of-counsel claim is a general claim that consists of several different allegations or subcategories, and, for purposes of the pleading requirements in Rule 32.3 and Rule 32.6(b), '[e]ach subcategory is [considered] *1189 a[n] independent claim that must be sufficiently pleaded.' Coral v. State , 900 So.2d 1274 , 1284 (Ala.Crim.App.2004), overruled on other grounds, Ex parte Jenkins , 972 So.2d 159 (Ala.2005)." Furthermore, in Taylor v. State

22016–2016
People v. Hernandez green
cal · 2004
22005–2012
Luke v. State green
alacrimapp · 1985
21998–2002
Ex Parte Hill green
ala · 1991
12023–2023
Clark v. State green
alacrimapp · 2015
12023–2023
Hill v. Lockhart green
scotus · 1985
12015–2015
Charlie Stith v. State of Alabama. green
alacrimapp · 2011
12015–2015
Whited v. State green
alacrimapp · 2014
12015–2015
Ex Parte Coleman green
ala · 2010
12015–2015
Lee v. State green
alacrimapp · 2009
12013–2013
Ross v. State green
alacrimapp · 1988
12013–2013
Allen v. State green
alacrimapp · 1985
12013–2013
Daniel v. State green
alacrimapp · 2011
12013–2013
Fortner v. State green
alacrimapp · 2001
12013–2013

Statutes the citing opinions construe

AL § Ala. Code § 13A-5-40 (33) AL § Ala. Code § 13A-5-49 (20) AL § Ala. Code § 13A-5-51 (17) AL § Ala. Code § 13A-5-47 (13) AL § Ala. Code § 13A-5-52 (13) AL § Ala. Code § 13A-5-53 (9) AL § Ala. Code § 13A-5-45 (8) AL § Ala. Code § 15-12-21 (7) AL § Ala. Code § 13A-5-46 (6) AL § Ala. Code § 13A-6-63 (6) AL § Ala. Code § 13A-6-66 (6) AL § Ala. Code § 13A-6-2 (5)

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 1531 (1989–2026) OH 1408 (1989–2026) TN 942 (1991–2026) IL 891 (1985–2026) PA 722 (1971–2026) WA 689 (1986–2026) MI 678 (1977–2026) GA 605 (1985–2026) IA 601 (1980–2026) CA 597 (1990–2026) MS 568 (1983–2026) ID 477 (1985–2026) UT 446 (1989–2026) WI 442 (1982–2026) NE 399 (1986–2026) MO 373 (1970–2025) FL 343 (1984–2026) IN 341 (1985–2026) NJ 279 (1986–2026) CT 219 (1985–2026) DE 200 (1990–2026) NY 179 (1987–2026) NC 167 (1981–2026) LA 163 (1983–2026) CO 158 (1985–2026) MN 157 (1991–2026) MA 146 (1988–2026) NM 145 (1989–2026) AL 131 (1985–2026) KS 130 (1994–2026) MT 120 (1991–2026) ND 108 (1987–2026) WV 82 (1982–2024) AZ 80 (1987–2026) AR 69 (1991–2026) KY 66 (1986–2026) OK 57 (1987–2026) MD 51 (1985–2025) NV 37 (1989–2022) DC 35 (1974–2026) HI 34 (1989–2024) WY 34 (1987–2025) VT 31 (1989–2025) SD 31 (1986–2026) NH 25 (1986–2023) SC 18 (2001–2025) ME 16 (1997–2018) VA 15 (1986–2023) AK 14 (1992–2025) RI 14 (1987–2012) OR 8 (2000–2025) VI 8 (2007–2026) GU 5 (2023–2025)

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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