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18 Kansas opinions name it 2 courts 2000–2025 4 in the last five years
The cases below were cited by Kansas 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 |
|---|---|---|
State v. Gleasongreen2 sentences2019Under this exception, as with the Cronic exception, reversal is automatic-unless the district court determines there is no conflict of interest. 296 Kan. at 183 [ 291 P.3d 62 ] ; see State v. Gleason , 277 Kan. 624 , 650, 88 P.3d 218 (2004). 2019Under this exception, as with the Cronic exception, reversal is automatic-unless the district court determines there is no conflict of interest. 296 Kan. at 183 [ 291 P.3d 62 ] ; see State v. Gleason , 277 Kan. 624 , 650, 88 P.3d 218 (2004). | 4 | 4 |
Florida v. Nixongreen2 sentences2024While his effort was brief, caselaw shows its importance to a Cronic analysis. 24 "Errors evaluated under Cronic are rare, and most alleged deficiencies are properly evaluated under Strickland rather than Cronic." State v. Adams, 297 Kan. 665, 670-71 , 304 P.3d 311 (2013); see also Florida v. Nixon, 543 U.S. 175, 190 , 125 S. Ct. 551 , 160 L. 2024While his effort was brief, caselaw shows its importance to a Cronic analysis. 24 "Errors evaluated under Cronic are rare, and most alleged deficiencies are properly evaluated under Strickland rather than Cronic." State v. Adams, 297 Kan. 665, 670-71 , 304 P.3d 311 (2013); see also Florida v. Nixon, 543 U.S. 175, 190 , 125 S. Ct. 551 , 160 L. | 2 | 4 |
State v. Cartergreen2 sentences2024See State v. Carter, 270 Kan. 426 , 14 P.3d 1138 (2000) (reaching a Cronic claim because the record on appeal could enable meaningful review of the claim). 2024See State v. Carter, 270 Kan. 426 , 14 P.3d 1138 (2000) (reaching a Cronic claim because the record on appeal could enable meaningful review of the claim). | 2 | 4 |
Edgar v. Stategreen2 sentences2020Cronic applies in rare circumstances: "This narrow exception, referred to as the Cronic exception, is 'reserved for situations in which counsel has entirely failed to function as the client's advocate.' The Supreme Court 8 has stressed this last point, emphasizing 'the attorney's failure must be complete,' that is, the Cronic-type presumption applies only '"if counsel entirely fails to subject the prosecution's case to meaningful adversarial testing."' [Citations omitted.]" Edgar v. State, 294 Kan. 828, 840 , 283 P.3d 152 (2012). 2020Cronic applies in rare circumstances: "This narrow exception, referred to as the Cronic exception, is 'reserved for situations in which counsel has entirely failed to function as the client's advocate.' The Supreme Court 8 has stressed this last point, emphasizing 'the attorney's failure must be complete,' that is, the Cronic-type presumption applies only '"if counsel entirely fails to subject the prosecution's case to meaningful adversarial testing."' [Citations omitted.]" Edgar v. State, 294 Kan. 828, 840 , 283 P.3d 152 (2012). | 1 | 4 |
United States v. Brent Paul Swansongreen2 sentences2012As in [United States v.] Swanson, [ 943 F.2d 1070, 1073-74 (9th Cir. 1991),] such a breakdown compels application of the Cronic exception. [See United States v. Cronic, 466 U.S. 648 , 104 S. Ct. 2039 , 80 L. 2012As in [United States v.] Swanson, [ 943 F.2d 1070, 1073-74 (9th Cir. 1991),] such a breakdown compels application of the Cronic exception. [See United States v. Cronic, 466 U.S. 648 , 104 S. Ct. 2039 , 80 L. | 1 | 2 |
Hamilton v. Alabamagreen2 sentences2024See Hamilton, 368 U.S. at 55 (presuming prejudice when counsel denied at arraignment because this was only time defendant could have asserted certain defenses). 2024See Hamilton, 368 U.S. at 55 (presuming prejudice when counsel denied at arraignment because this was only time defendant could have asserted certain defenses). | 1 | 1 |
Lingenfelter v. Stategreen2 sentences2020In Lingenfelter v. State, No. 102,391, 2010 WL 4320356, at *2 (Kan. 2020In Lingenfelter v. State, No. 102,391, 2010 WL 4320356, at *2 (Kan. | 1 | 1 |
United States v. Collinsgreen2 sentences2013See, e.g., United States v. Collins, 430 F.3d 1260 (10th Cir. 2005) (attorney, who had filed motion to withdraw, declined to comment at defendant’s competency hearing and mentioned he possessed probative evidence but did not introduce it; court held right to counsel denied because no meaningful adversarial testing); Tucker v. Day, 969 F.2d 155, 159 (5th Cir. 1992) (finding appointed counsel at re-sentencing hearing was ineffective under Cronic because he did not consult with defendant, had scant knowledge of facts, and made no helpful comments at sentencing); see also State v. Carter, 270 Kan. 2013See, e.g., United States v. Collins, 430 F.3d 1260 (10th Cir. 2005) (attorney, who had filed motion to withdraw, declined to comment at defendant’s competency hearing and mentioned he possessed probative evidence but did not introduce it; court held right to counsel denied because no meaningful adversarial testing); Tucker v. Day, 969 F.2d 155, 159 (5th Cir. 1992) (finding appointed counsel at re-sentencing hearing was ineffective under Cronic because he did not consult with defendant, had scant knowledge of facts, and made no helpful comments at sentencing); see also State v. Carter, 270 Kan. | 1 | 1 |
Raymond Alton Tucker v. Ed Day, Wardengreen2 sentences2013See, e.g., United States v. Collins, 430 F.3d 1260 (10th Cir. 2005) (attorney, who had filed motion to withdraw, declined to comment at defendant’s competency hearing and mentioned he possessed probative evidence but did not introduce it; court held right to counsel denied because no meaningful adversarial testing); Tucker v. Day, 969 F.2d 155, 159 (5th Cir. 1992) (finding appointed counsel at re-sentencing hearing was ineffective under Cronic because he did not consult with defendant, had scant knowledge of facts, and made no helpful comments at sentencing); see also State v. Carter, 270 Kan. 2013See, e.g., United States v. Collins, 430 F.3d 1260 (10th Cir. 2005) (attorney, who had filed motion to withdraw, declined to comment at defendant’s competency hearing and mentioned he possessed probative evidence but did not introduce it; court held right to counsel denied because no meaningful adversarial testing); Tucker v. Day, 969 F.2d 155, 159 (5th Cir. 1992) (finding appointed counsel at re-sentencing hearing was ineffective under Cronic because he did not consult with defendant, had scant knowledge of facts, and made no helpful comments at sentencing); see also State v. Carter, 270 Kan. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
United States v. Cronic
green
2 sentences2025Lara-Lopez argues that this court should apply the Cronic test, which applies when a defendant suffers a "'complete denial of the assistance of counsel . . . at a critical stage of a [criminal] proceeding.'" State v. McDaniel, 306 Kan. 595 , 608, 395 P.3d 429 (2017) (citing United States v. Cronic, 466 U.S. 648, 658-59 , 104 S. Ct. 2039 , 80 L. 2025Lara-Lopez argues that this court should apply the Cronic test, which applies when a defendant suffers a "'complete denial of the assistance of counsel . . . at a critical stage of a [criminal] proceeding.'" State v. McDaniel, 306 Kan. 595 , 608, 395 P.3d 429 (2017) (citing United States v. Cronic, 466 U.S. 648, 658-59 , 104 S. Ct. 2039 , 80 L. | 10 | 2012–2025 |
State v. Galaviz
green
2 sentences2019Under this exception, as with the Cronic exception, reversal is automatic-unless the district court determines there is no conflict of interest. 296 Kan. at 183 [ 291 P.3d 62 ] ; see State v. Gleason , 277 Kan. 624 , 650, 88 P.3d 218 (2004). 2019Under this exception, as with the Cronic exception, reversal is automatic-unless the district court determines there is no conflict of interest. 296 Kan. at 183 [ 291 P.3d 62 ] ; see State v. Gleason , 277 Kan. 624 , 650, 88 P.3d 218 (2004). | 4 | 2014–2019 |
Bell v. Cone
green
2 sentences2024There, the United States Supreme Court explained that establishing a presumption of prejudice under the Cronic exception requires a showing of "the 'complete denial of counsel'" and allegations of error at specific points in the attorney's representation do not qualify. 535 U.S. at 695 . 2024There, the United States Supreme Court explained that establishing a presumption of prejudice under the Cronic exception requires a showing of "the 'complete denial of counsel'" and allegations of error at specific points in the attorney's representation do not qualify. 535 U.S. at 695 . | 3 | 2012–2024 |
Mickens v. Taylor
green
2 sentences2014The present appeal falls into the second Mickens category'—the Cronic exception—where the complete denial of the assistance of counsel or tire denial of counsel at a critical stage of the proceedings presents “ ‘circumstances of [such] magnitude’ ” that a court “presumes a probable effect upon the outcome” and “a case-by-case inquiry [of prejudice] is unnecessary.” Mickens, 535 U.S. at 166 (citing Cronic, 466 U.S. at 658-59 ). 2014The present appeal falls into the second Mickens category'—the Cronic exception—where the complete denial of the assistance of counsel or tire denial of counsel at a critical stage of the proceedings presents “ ‘circumstances of [such] magnitude’ ” that a court “presumes a probable effect upon the outcome” and “a case-by-case inquiry [of prejudice] is unnecessary.” Mickens, 535 U.S. at 166 (citing Cronic, 466 U.S. at 658-59 ). | 2 | 2012–2014 |
Strickland v. Washington
green
2 sentences2024Instead, specific complaints are handled under the general rules for evaluating counsel's performance established in Strickland v. Washington, 466 U.S. 668 , 104 S. Ct. 2052 , 80 L. 2024Instead, specific complaints are handled under the general rules for evaluating counsel's performance established in Strickland v. Washington, 466 U.S. 668 , 104 S. Ct. 2052 , 80 L. | 1 | 2024–2024 |
State v. Adams
green
2 sentences2024While his effort was brief, caselaw shows its importance to a Cronic analysis. 24 "Errors evaluated under Cronic are rare, and most alleged deficiencies are properly evaluated under Strickland rather than Cronic." State v. Adams, 297 Kan. 665, 670-71 , 304 P.3d 311 (2013); see also Florida v. Nixon, 543 U.S. 175, 190 , 125 S. Ct. 551 , 160 L. 2024While his effort was brief, caselaw shows its importance to a Cronic analysis. 24 "Errors evaluated under Cronic are rare, and most alleged deficiencies are properly evaluated under Strickland rather than Cronic." State v. Adams, 297 Kan. 665, 670-71 , 304 P.3d 311 (2013); see also Florida v. Nixon, 543 U.S. 175, 190 , 125 S. Ct. 551 , 160 L. | 1 | 2024–2024 |
Trotter v. State
green
2 sentences2024Trotter, 288 Kan. 112 , Syl. ¶ 10. 2024Trotter, 288 Kan. 112 , Syl. ¶ 10. | 1 | 2024–2024 |
Fuller v. State
green
2 sentences2020Under the so-called Cronic exception, a court presumes prejudice and a movant "is 'spared . . . the need of showing probable effect upon the outcome.'" Fuller, 303 Kan. at 487 . 2020Under the so-called Cronic exception, a court presumes prejudice and a movant "is 'spared . . . the need of showing probable effect upon the outcome.'" Fuller, 303 Kan. at 487 . | 1 | 2020–2020 |
In the Interest of Rushing
green
2 sentences2017In Rushing, the court did apply the Cronic exception to the parental severance case because the father's attorney left the courtroom "mid-trial" and was not present during much of the evidentiary hearing, the evidence of father's unfitness was "marginal at best," and the attorney made no argument to the trial judge concerning the sufficiency of the evidence. 9 Kan. 2017In Rushing, the court did apply the Cronic exception to the parental severance case because the father's attorney left the courtroom "mid-trial" and was not present during much of the evidentiary hearing, the evidence of father's unfitness was "marginal at best," and the attorney made no argument to the trial judge concerning the sufficiency of the evidence. 9 Kan. | 1 | 2017–2017 |
Jaramillo v. Pinkerton
neutral
2 sentences2014Ed. 2d 914 , reh. denied 536 U.S. 976 (2002). 2014Ed. 2d 914 , reh. denied 536 U.S. 976 (2002). | 1 | 2014–2014 |
Holloway v. Arkansas
green
2 sentences2012Mickens, 535 U.S. at 168 (citing Holloway, 435 U.S. at 488 ); see Gleason, 277 Kan. at 650 . 2012Mickens, 535 U.S. at 168 (citing Holloway, 435 U.S. at 488 ); see Gleason, 277 Kan. at 650 . | 1 | 2012–2012 |
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.