deficiency prejudiced defense (Wisconsin) · Go Syfert
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deficiency prejudiced defense in Wisconsin

99 Wisconsin opinions name it 2 courts 1990–2026 47 in the last five years

The cases below were cited by Wisconsin 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 (15)

CaseFollowedCited
Strickland v. Washingtongreen
scotus · 1984 · cited in 84 Wisconsin opinions naming this issue, 1990–2026
2 sentences

2025However, Anthony’s allegations are inadequate to demonstrate that postconviction counsel’s performance was deficient and that the deficiency prejudiced his defense, as required by the two-prong ineffective assistance of counsel test in Strickland v. Washington, 466 U.S. 668, 687 (1984). ¶10 Anthony’s allegations are conclusory and opinion framed as factual allegations.

2024To establish ineffective assistance of counsel, a defendant must prove both (1) “that counsel’s performance was deficient” and (2) “that the deficiency prejudiced the defense.” State v. Carter, 2010 WI 40, ¶21 , 324 Wis. 2d 640 , 782 N.W.2d 695 (quoting Strickland v. Washington, 466 U.S. 668, 687 (1984)).

6884
State v. Balliettegreen
wis · 2011 · cited in 3 Wisconsin opinions naming this issue, 2019–2020
2 sentences

2020See State v. Balliette, 2011 WI 79, ¶21 , 336 Wis. 2d 358 , 805 N.W.2d 334 .

2020See State v. Balliette, 2011 WI 79, ¶21 , 336 Wis. 2d 358 , 805 N.W.2d 334 .

33
State v. Johnsongreen
wis · 1990 · cited in 3 Wisconsin opinions naming this issue, 1993–2021
2 sentences

2021“Even if deficient performance is found, judgment will not be reversed unless the defendant proves that the deficiency prejudiced his defense.” State v. Johnson, 153 Wis. 2d 121, 127 , 449 N.W.2d 845 (1990).

2021“Even if deficient performance is found, judgment will not be reversed unless the defendant proves that the deficiency prejudiced his defense.” State v. Johnson, 153 Wis. 2d 121, 127 , 449 N.W.2d 845 (1990).

23
State v. Mayogreen
wis · 2007 · cited in 2 Wisconsin opinions naming this issue, 2018–2020
2 sentences

2020See State v. Mayo, 2007 WI 78, ¶33 , 301 Wis. 2d 642 , 734 N.W.2d 115 .

2020See State v. Mayo, 2007 WI 78, ¶33 , 301 Wis. 2d 642 , 734 N.W.2d 115 .

22
State v. Cartergreen
wis · 2010 · cited in 5 Wisconsin opinions naming this issue, 2017–2024
2 sentences

2024To establish ineffective assistance of counsel, a defendant must prove both (1) “that counsel’s performance was deficient” and (2) “that the deficiency prejudiced the defense.” State v. Carter, 2010 WI 40, ¶21 , 324 Wis. 2d 640 , 782 N.W.2d 695 (quoting Strickland v. Washington, 466 U.S. 668, 687 (1984)).

2024To establish ineffective assistance of counsel, a defendant must prove both (1) “that counsel’s performance was deficient” and (2) “that the deficiency prejudiced the defense.” State v. Carter, 2010 WI 40, ¶21 , 324 Wis. 2d 640 , 782 N.W.2d 695 (quoting Strickland v. Washington, 466 U.S. 668, 687 (1984)).

15
State v. Myron C. Dillardgreen
wis · 2014 · cited in 3 Wisconsin opinions naming this issue, 2019–2024
2 sentences

2021State v. Dillard, 2014 WI 123, ¶84 , 358 Wis. 2d 543 , 859 N.W.2d 44 . ¶42 To establish ineffective assistance, a defendant must prove: (1) that trial counsel’s performance was deficient; and (2) that the deficiency prejudiced the defense.

2021State v. Dillard, 2014 WI 123, ¶84 , 358 Wis. 2d 543 , 859 N.W.2d 44 . ¶42 To establish ineffective assistance, a defendant must prove: (1) that trial counsel’s performance was deficient; and (2) that the deficiency prejudiced the defense.

13
United States v. Cronicgreen
scotus · 1984 · cited in 1 Wisconsin opinions naming this issue, 2026–2026
1 sentence

2026Id. at 687 . ¶12 While V.T. argues that Strickland does not apply to this case, and that we should presume prejudice under United States v. Cronic, 466 U.S. 648, 661 (1984), we disagree.

11
A.O. Smith Corp. v. Allstate Insurancegreen
wisctapp · 1998 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
2 sentences

2024Cos., 222 Wis. 2d 475, 491 , 588 N.W.2d 285 (Ct. App. 1998) (“[A]n issue raised in the [circuit] court, but not raised on appeal, is deemed abandoned.”). 8 No. 2021AP1346-CR DISCUSSION ¶18 To succeed on an ineffective assistance of counsel claim, a defendant must show that his or her counsel’s performance was deficient and that the deficiency prejudiced the defense.

2024Cos., 222 Wis. 2d 475, 491 , 588 N.W.2d 285 (Ct. App. 1998) (“[A]n issue raised in the [circuit] court, but not raised on appeal, is deemed abandoned.”). 8 No. 2021AP1346-CR DISCUSSION ¶18 To succeed on an ineffective assistance of counsel claim, a defendant must show that his or her counsel’s performance was deficient and that the deficiency prejudiced the defense.

11
State v. Shane Allan Stroikgreen
wisctapp · 2022 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
2 sentences

2024See State v. Stroik, 2022 WI App 11, ¶65 , 401 Wis. 2d 150 , 972 N.W.2d 640 (concluding that a defendant’s trial counsel performed deficiently at a jury trial and that the deficiency prejudiced the defense because, among other things, “[t]here was no physical evidence or witnesses to the alleged assault, and [the defendant] consistently denied the allegations”). ¶49 Furthermore, contrary to the State’s assertion, Molde did offer a theory as to why Lauren would falsely accuse him.

2024See State v. Stroik, 2022 WI App 11, ¶65 , 401 Wis. 2d 150 , 972 N.W.2d 640 (concluding that a defendant’s trial counsel performed deficiently at a jury trial and that the deficiency prejudiced the defense because, among other things, “[t]here was no physical evidence or witnesses to the alleged assault, and [the defendant] consistently denied the allegations”). ¶49 Furthermore, contrary to the State’s assertion, Molde did offer a theory as to why Lauren would falsely accuse him.

11
State v. Howellgreen
wis · 2007 · cited in 1 Wisconsin opinions naming this issue, 2020–2020
2 sentences

2020See State v. Howell, 2007 WI 75, ¶74 , 301 Wis. 2d 350 , 734 N.W.2d 48 . 5 No. 2018AP2171-CR ¶11 To prevail on a claim of ineffective assistance of counsel, a defendant must establish both that counsel’s performance was deficient and that the deficiency prejudiced the defense.

2020See State v. Howell, 2007 WI 75, ¶74 , 301 Wis. 2d 350 , 734 N.W.2d 48 . 5 No. 2018AP2171-CR ¶11 To prevail on a claim of ineffective assistance of counsel, a defendant must establish both that counsel’s performance was deficient and that the deficiency prejudiced the defense.

11
State v. Joseph B. Reinwandgreen
wis · 2019 · cited in 1 Wisconsin opinions naming this issue, 2020–2020
1 sentence

2020Reinwand, 385 Wis. 2d 700, ¶¶40, 42 . ¶80 The deficiency prong requires the defendant to prove “that the defendant’s attorney ‘made errors so serious that counsel was not functioning as the counsel guaranteed the defendant by the Sixth Amendment.’” State v. Starks, 2013 WI 69, ¶54 , 349 Wis. 2d 274 , 833 N.W.2d 146 (quoting Strickland, 466 U.S. at 687 ).

11
State v. Ginger M. Breitzmangreen
wis · 2017 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
2 sentences

2018See State v. Breitzman , 2017 WI 100 , ¶ 37, 378 Wis. 2d 431 , 904 N.W.2d 93 , cert. denied , 138 S. Ct. 1599 (2018).

2018See State v. Breitzman , 2017 WI 100 , ¶ 37, 378 Wis. 2d 431 , 904 N.W.2d 93 , cert. denied , 138 S. Ct. 1599 (2018).

11
Morgan v. Kansasgreen
scotus · 2018 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
1 sentence

2018See State v. Breitzman , 2017 WI 100 , ¶ 37, 378 Wis. 2d 431 , 904 N.W.2d 93 , cert. denied , 138 S. Ct. 1599 (2018).

11
State v. Thielgreen
wis · 2003 · cited in 1 Wisconsin opinions naming this issue, 2017–2017
2 sentences

2017With regard to the first part of this test, ''[c]ounsel's conduct is constitutionally deficient if it falls below an objective standard of reasonableness." Thiel, 264 Wis. 2d 571, ¶ 19 (citing Strickland, 466 U.S. at 688 ).

2017With regard to the first part of this test, "[c]ounsel's conduct is constitutionally deficient if it falls below an objective standard of reasonableness." Thiel, 264 Wis. 2d 571, ¶19 (citing Strickland, 466 U.S. at 688 ).

11
Bose Corp. v. Consumers Union of United States, Inc.green
scotus · 1984 · cited in 1 Wisconsin opinions naming this issue, 1996–1996
2 sentences

1996See Strickland v. Washington, 466 U.S. 668, 687 , rehearing denied 467 U.S. 1267 (1984).

1996See Strickland v. Washington, 466 U.S. 668, 687 , rehearing denied 467 U.S. 1267 (1984).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
State v. Villegas green
wisctapp · 2018
2 sentences

2024State v. Villegas, 2018 WI App 9, ¶23 , 380 Wis. 2d 246 , 908 N.W.2d 198 .

2024State v. Villegas, 2018 WI App 9, ¶23 , 380 Wis. 2d 246 , 908 N.W.2d 198 .

32019–2024
State v. Gerald D. Taylor green
wis · 2013
2 sentences

2022Although a manifest injustice as it relates to plea withdrawal may be demonstrated by proving ineffective assistance of counsel, see State v. Taylor, 2013 WI 34, ¶49 , 347 Wis. 2d 30 , 829 N.W.2d 482 , to succeed on such a claim, the defendant must prove both prongs of the Strickland7 test—that his or her trial counsel’s performance was deficient and that the deficiency prejudiced the defense—in order to prevail.

2022Although a manifest injustice as it relates to plea withdrawal may be demonstrated by proving ineffective assistance of counsel, see State v. Taylor, 2013 WI 34, ¶49 , 347 Wis. 2d 30 , 829 N.W.2d 482 , to succeed on such a claim, the defendant must prove both prongs of the Strickland7 test—that his or her trial counsel’s performance was deficient and that the deficiency prejudiced the defense—in order to prevail.

32021–2022
State v. Love green
wis · 2005
2 sentences

2018Strickland v. Washington , 466 U.S. 668 , 687 (1984). ¶ 18 "To prove constitutional deficiency, the defendant must establish that counsel's conduct falls below an objective standard of reasonableness." State v. Love , 2005 WI 116 , ¶ 30, 284 Wis. 2d 111 , 700 N.W.2d 62 .

2018Strickland v. Washington , 466 U.S. 668 , 687 (1984). ¶ 18 "To prove constitutional deficiency, the defendant must establish that counsel's conduct falls below an objective standard of reasonableness." State v. Love , 2005 WI 116 , ¶ 30, 284 Wis. 2d 111 , 700 N.W.2d 62 .

22018–2018
State v. Allen green
wis · 2004
2 sentences

2022State v. Allen, 2004 WI 106, ¶26 , 274 Wis. 2d 568 , 682 N.W.2d 433 .

2022State v. Allen, 2004 WI 106, ¶26 , 274 Wis. 2d 568 , 682 N.W.2d 433 .

12022–2022
State v. Ziebart green
wisctapp · 2003
2 sentences

2020However, to prove that his appellate counsel was ineffective for failing to bring the ineffective assistance of trial counsel claims, Johnson “bears the 4 No. 2018AP971 burden of proving that trial counsel’s performance was deficient and prejudicial.” See State v. Ziebart, 2003 WI App 258, ¶15 , 268 Wis. 2d 468 , 673 N.W.2d 369 . ¶10 To prove ineffective assistance of counsel, a defendant must show both that counsel’s performance was deficient and that the deficiency prejudiced his defense.

2020However, to prove that his appellate counsel was ineffective for failing to bring the ineffective assistance of trial counsel claims, Johnson “bears the 4 No. 2018AP971 burden of proving that trial counsel’s performance was deficient and prejudicial.” See State v. Ziebart, 2003 WI App 258, ¶15 , 268 Wis. 2d 468 , 673 N.W.2d 369 . ¶10 To prove ineffective assistance of counsel, a defendant must show both that counsel’s performance was deficient and that the deficiency prejudiced his defense.

12020–2020
State v. Tramell E. Starks green
wis · 2013
2 sentences

2020Reinwand, 385 Wis. 2d 700, ¶¶40, 42 . ¶80 The deficiency prong requires the defendant to prove “that the defendant’s attorney ‘made errors so serious that counsel was not functioning as the counsel guaranteed the defendant by the Sixth Amendment.’” State v. Starks, 2013 WI 69, ¶54 , 349 Wis. 2d 274 , 833 N.W.2d 146 (quoting Strickland, 466 U.S. at 687 ).

2020Reinwand, 385 Wis. 2d 700, ¶¶40, 42 . ¶80 The deficiency prong requires the defendant to prove “that the defendant’s attorney ‘made errors so serious that counsel was not functioning as the counsel guaranteed the defendant by the Sixth Amendment.’” State v. Starks, 2013 WI 69, ¶54 , 349 Wis. 2d 274 , 833 N.W.2d 146 (quoting Strickland, 466 U.S. at 687 ).

12020–2020
State v. Jimothy A. Jenkins green
wis · 2014
1 sentence

2020Strickland v. Washington, 466 U.S. 668, 687 (1984); Jenkins, 355 Wis. 2d 180, ¶35 .

12020–2020
State v. Kuhn green
wisctapp · 1993
2 sentences

2003See Strickland v. Washington, 466 U.S. 668, 687 (1984); State v. Kuhn, 178 Wis. 2d 428, 437 , 504 N.W.2d 405 (Ct. App. 1993).

2003See Strickland v. Washington, 466 U.S. 668, 687 (1984); State v. Kuhn, 178 Wis. 2d 428, 437 , 504 N.W.2d 405 (Ct. App. 1993).

12003–2003

Statutes the citing opinions construe

WI § Wis. Stat. § 808.10 (74) WI § Wis. Stat. § 974.06 (13) WI § Wis. Stat. § 908.01 (10) WI § Wis. Stat. § 752.35 (7) WI § Wis. Stat. § 940.01 (7) WI § Wis. Stat. § 941.29 (7) WI § Wis. Stat. § 971.08 (7) WI § Wis. Stat. § 904.04 (6) WI § Wis. Stat. § 972.11 (6) WI § Wis. Stat. § 971.12 (5) WI § Wis. Stat. § 904.03 (4) WI § Wis. Stat. § 961.41 (4)

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

TN 604 (1987–2026) MS 429 (1991–2026) GA 271 (1985–2025) TX 168 (1990–2026) WI 99 (1990–2026) CA 59 (1995–2026) MO 35 (1988–2025) FL 27 (2000–2025) NJ 26 (2018–2026) IL 25 (1989–2024) WA 16 (2003–2021) OH 14 (2004–2026) NM 10 (2002–2024) LA 10 (1987–2025) KY 7 (2021–2025) MT 5 (2013–2024) OK 5 (1987–2004) ID 4 (1994–2019) NC 4 (2005–2025) DC 4 (1992–2021) SC 4 (1989–2025) MD 4 (1999–2003) AR 4 (2021–2025) VA 3 (1986–2006) NV 3 (1992–2016) MN 3 (2011–2015) PA 3 (1986–1987) WY 2 (1987–2005) AL 2 (2001–2005)

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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