19 Michigan opinions name it 2 courts 2007–2026 7 in the last five years
The cases below were cited by Michigan 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 |
|---|---|---|
People v. Fraziergreen2 sentences2026See also Frazier, 478 Mich at 244 (“The Cronic test applies when the attorney’s failure is complete, while the Strickland test applies when counsel failed at specific points of the proceeding.”). 2026See also Frazier, 478 Mich at 244 (“The Cronic test applies when the attorney’s failure is complete, while the Strickland test applies when counsel failed at specific points of the proceeding.”). | 4 | 15 |
United States v. Cronicgreen2 sentences2011But the United States Supreme Court did not state that the Cronic test applied only to those situations where there was no adversarial testing whatsoever-, rather, it very clearly stated that there had to be a total failure to subject the prosecution’s case to “meaningful adversarial testing.” Cronic, 466 US at 659 (emphasis added). 2011But the United States Supreme Court did not state that the Cronic test applied only to those situations where there was no adversarial testing whatsoever-, rather, it very clearly stated that there had to be a total failure to subject the prosecution’s case to “meaningful adversarial testing.” Cronic, 466 US at 659 (emphasis added). | 1 | 4 |
Florida v. Nixongreen2 sentences2017See also Florida v Nixon, 543 US 175, 189 ; 125 S Ct 551 ; 160 L Ed 2d 565 (2004) (noting that the Cronic presumption of prejudice is “reserved for situations in which counsel has entirely failed to function as the client’s advocate.”) (emphasis added). 2017See also Florida v Nixon, 543 US 175, 189 ; 125 S Ct 551 ; 160 L Ed 2d 565 (2004) (noting that the Cronic presumption of prejudice is “reserved for situations in which counsel has entirely failed to function as the client’s advocate.”) (emphasis added). | 1 | 1 |
Burdine v. Johnsongreen2 sentences2011Burdine v Johnson, 262 F3d 336, 349 (CA 5, 2001). 2011Burdine v Johnson, 262 F3d 336, 349 (CA 5, 2001). | 1 | 1 |
Ronald Eugene Rickman, Petitioner-Appellee/cross-Appellant v. Ricky Bell, Warden, Respondent-Appellant/cross-Appellantgreen2 sentences2011In contrast, in Rickman v Bell, 131 F3d 1150, 1157, 1160 (CA 6, 1997) the United States Court of Appeals for the Sixth Circuit concluded that there was a Cronic violation as a result of a failure to meaningfully test the prosecution’s case when the defense counsel “combined a total failure to actively advocate his client’s cause with repeated expressions of contempt for his client for his alleged actions” to the jury. 2011In contrast, in Rickman v Bell, 131 F3d 1150, 1157, 1160 (CA 6, 1997) the United States Court of Appeals for the Sixth Circuit concluded that there was a Cronic violation as a result of a failure to meaningfully test the prosecution’s case when the defense counsel “combined a total failure to actively advocate his client’s cause with repeated expressions of contempt for his client for his alleged actions” to the jury. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Bell v. Cone
green
2 sentences2020“The Cronic test applies when the attorney’s failure is complete, while the Strickland test applies when counsel failed at specific points of the proceeding.” Frazier, 478 Mich at 244 , citing Bell, 535 US at 697 . 2020“The Cronic test applies when the attorney’s failure is complete, while the Strickland test applies when counsel failed at specific points of the proceeding.” Frazier, 478 Mich at 244 , citing Bell, 535 US at 697 . | 8 | 2007–2020 |
Woods v. Donald
green
2 sentences2020“Cronic applies in ‘circumstances that are so likely to prejudice the accused that the cost of litigating their effect in a particular case is unjustified.’ ” Woods v Donald, __ US __, __; 135 S Ct 1372 , 1378; 191 L Ed 2d 464 (2015), citing Cronic, 466 US at 658 . -6- During trial, defense counsel conducted voir dire, cross-examined the prosecution’s witnesses, and made an opening statement and closing argument wherein he advocated for defendant’s acquittal. 2020“Cronic applies in ‘circumstances that are so likely to prejudice the accused that the cost of litigating their effect in a particular case is unjustified.’ ” Woods v Donald, __ US __, __; 135 S Ct 1372 , 1378; 191 L Ed 2d 464 (2015), citing Cronic, 466 US at 658 . -6- During trial, defense counsel conducted voir dire, cross-examined the prosecution’s witnesses, and made an opening statement and closing argument wherein he advocated for defendant’s acquittal. | 3 | 2018–2020 |
Strickland v. Washington
green
2 sentences2023“The Cronic test applies when the attorney’s failure is complete, while the Strickland test[, Strickland v Washington, 466 US 668 ; 104 S Ct 2052 ; 80 L Ed 2d 674 (1984),] applies when counsel failed at specific points of the proceeding.” People v Frazier, 478 Mich 231, 244 ; 733 NW2d 713 (2007). 2023“The Cronic test applies when the attorney’s failure is complete, while the Strickland test[, Strickland v Washington, 466 US 668 ; 104 S Ct 2052 ; 80 L Ed 2d 674 (1984),] applies when counsel failed at specific points of the proceeding.” People v Frazier, 478 Mich 231, 244 ; 733 NW2d 713 (2007). | 2 | 2023–2023 |
People v. Horn
green
2 sentences2018However, as stated, the claimed deficiency is “not apparent from the record,” and, therefore, under the Cronic standard as well, it is “not subject to our review.” People v Horn, 279 Mich App 31, 38 ; 755 NW2d 212 (2008). -6- 2018However, as stated, the claimed deficiency is “not apparent from the record,” and, therefore, under the Cronic standard as well, it is “not subject to our review.” People v Horn, 279 Mich App 31, 38 ; 755 NW2d 212 (2008). -6- | 1 | 2018–2018 |
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.