Sixth Amendment violation (Arkansas) · Go Syfert
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Sixth Amendment violation in Arkansas

13 Arkansas opinions name it 2 courts 1988–2026 2 in the last five years

The cases below were cited by Arkansas 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 (7)

CaseFollowedCited
United States v. Gonzalez-Lopezgreen
scotus · 2006 · cited in 2 Arkansas opinions naming this issue, 2013–2022
2 sentences

2022This was so because when the “right to be assisted by counsel of one’s choice is wrongly denied . . . it is unnecessary to conduct an ineffectiveness or prejudice inquiry to establish a Sixth Amendment violation.” Id. (quoting United States v. Gonzalez-Lopez, 548 U.S. 140, 148 (2006)).

2022This was so because when the “right to be assisted by counsel of one’s choice is wrongly denied . . . it is unnecessary to conduct an ineffectiveness or prejudice inquiry to establish a Sixth Amendment violation.” Id. (quoting United States v. Gonzalez-Lopez, 548 U.S. 140, 148 (2006)).

12
Wayne Kieser v. The People of the State of New Yorkgreen
ca2 · 1995 · cited in 1 Arkansas opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., Kieser v. People of New York, 56 F.3d 16 (2d Cir.1995); United States v. Costanzo, 740 F.2d 251 (3d Cir.1984); Derringer v. United States, 441 F.2d 1140 (8th Cir.1971); United States v. Bradford, 238 F.2d 395 (2d Cir.1956).

11
Paul Peter Solina, Jr. v. United Statesgreen
ca2 · 1983 · cited in 1 Arkansas opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., Solina v. United States, 709 F.2d 160 (2d Cir.1983) (representation by person who had failed twice to pass the New York state bar examination and was not a member of any other bar was a per se violation of the right to counsel); cf. United States v. Novak, 903 F.2d 883 (2d Cir.1990) (representation by attorney who gained law license through fraud was a per se Sixth Amendment violation).

11
United States v. Yelverton, Willie L.green
cadc · 1999 · cited in 1 Arkansas opinions naming this issue, 2004–2004
2 sentences

2004Therefore, it is highly inappropriate to base this decision on a due process argument. [3] In United States v. Yelverton, 197 F.3d 531 (D.C.App.1999), the United States Court of Appeals for the District of Columbia Circuit noted in a footnote that "mere generalized anxiety is insufficient to establish prejudice, even when such anxiety is due to a pre-trial delay in excess of four years.... [A]bsent evidence of severe anxiety ..., we are left with what amounts to rank speculation about Yelverton's general state of mind, and this is insufficient to establish a Sixth Amendment violation." Yelvert

2004Therefore, it is highly inappropriate to base this decision on a due process argument. [3] In United States v. Yelverton, 197 F.3d 531 (D.C.App.1999), the United States Court of Appeals for the District of Columbia Circuit noted in a footnote that "mere generalized anxiety is insufficient to establish prejudice, even when such anxiety is due to a pre-trial delay in excess of four years.... [A]bsent evidence of severe anxiety ..., we are left with what amounts to rank speculation about Yelverton's general state of mind, and this is insufficient to establish a Sixth Amendment violation." Yelvert

11
United States v. Loud Hawkgreen
scotus · 1986 · cited in 1 Arkansas opinions naming this issue, 2004–2004
2 sentences

2004While such presumptive prejudice cannot alone carry a Sixth Amendment claim without regard to the other Barker criteria, see Loud Hawk, supra, at 315 [ 106 S.Ct. 648 ], it is part of the mix of relevant facts, and its importance increases with the length of delay.

2004While such presumptive prejudice cannot alone carry a Sixth Amendment claim without regard to the other Barker criteria, see Loud Hawk, supra, at 315 [ 106 S.Ct. 648 ], it is part of the mix of relevant facts, and its importance increases with the length of delay.

11
Strickland v. Washingtongreen
scotus · 1984 · cited in 1 Arkansas opinions naming this issue, 2003–2003
2 sentences

2003Generally, a defendant alleging a Sixth Amendment violation must demonstrate “a reasonable probability that, but for counsel’s unprofesr sional errors, the result of the proceeding would have been different.” Mickens v. Taylor, 535 U.S. 162, 166 (2002) (quoting Strickland v. Washington, 466 U.S. 668, 694 (1984)).

2003Generally, a defendant alleging a Sixth Amendment violation must demonstrate “a reasonable probability that, but for counsel’s unprofesr sional errors, the result of the proceeding would have been different.” Mickens v. Taylor, 535 U.S. 162, 166 (2002) (quoting Strickland v. Washington, 466 U.S. 668, 694 (1984)).

11
Mickens v. Taylorgreen
scotus · 2002 · cited in 1 Arkansas opinions naming this issue, 2003–2003
2 sentences

2003Generally, a defendant alleging a Sixth Amendment violation must demonstrate “a reasonable probability that, but for counsel’s unprofesr sional errors, the result of the proceeding would have been different.” Mickens v. Taylor, 535 U.S. 162, 166 (2002) (quoting Strickland v. Washington, 466 U.S. 668, 694 (1984)).

2003Generally, a defendant alleging a Sixth Amendment violation must demonstrate “a reasonable probability that, but for counsel’s unprofesr sional errors, the result of the proceeding would have been different.” Mickens v. Taylor, 535 U.S. 162, 166 (2002) (quoting Strickland v. Washington, 466 U.S. 668, 694 (1984)).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (15)

CaseCitedYears
Crawford v. Washington green
scotus · 2004
2 sentences

2026Johnson’s remark was a casual observation made to his cousin during a private phone call—precisely the kind of nontestimonial statement that Crawford v. Washington, 541 U.S. 36 (2004), and Davis v. Washington, 547 U.S. 813 (2006), place outside the Confrontation Clause’s reach—made with no purpose of creating evidence for prosecution and with no reasonable anticipation that the exchange would ever be used at trial.

2015Id.

22015–2026
Davis v. Washington green
scotus · 2006
1 sentence

2026Johnson’s remark was a casual observation made to his cousin during a private phone call—precisely the kind of nontestimonial statement that Crawford v. Washington, 541 U.S. 36 (2004), and Davis v. Washington, 547 U.S. 813 (2006), place outside the Confrontation Clause’s reach—made with no purpose of creating evidence for prosecution and with no reasonable anticipation that the exchange would ever be used at trial.

12026–2026
Arroyo v. State green
ark · 2013
2 sentences

2022This was so because when the “right to be assisted by counsel of one’s choice is wrongly denied . . . it is unnecessary to conduct an ineffectiveness or prejudice inquiry to establish a Sixth Amendment violation.” Id. (quoting United States v. Gonzalez-Lopez, 548 U.S. 140, 148 (2006)).

2022This was so because when the “right to be assisted by counsel of one’s choice is wrongly denied . . . it is unnecessary to conduct an ineffectiveness or prejudice inquiry to establish a Sixth Amendment violation.” Id. (quoting United States v. Gonzalez-Lopez, 548 U.S. 140, 148 (2006)).

12022–2022
United States v. Cronic green
scotus · 1984
2 sentences

2018In Cronic , the Supreme Court held, "Only when surrounding circumstances justify a presumption of ineffectiveness can a Sixth Amendment claim be sufficient without inquiry into counsel's actual performance at trial." Id. at 667 , 104 S.Ct. 2039 .

2018In Cronic , the Supreme Court held, "Only when surrounding circumstances justify a presumption of ineffectiveness can a Sixth Amendment claim be sufficient without inquiry into counsel's actual performance at trial." Id. at 667 , 104 S.Ct. 2039 .

12018–2018
Harris v. State green
ark · 2005
2 sentences

2012This court rejected this argument and held that “the matter clearly does not fall within any of the Wicks exceptions.” Harris, 363 Ark. at 505 , 215 S.W.3d at 668 .

2012This court rejected this argument and held that “the matter clearly does not fall within any of the Wicks exceptions.” Harris, 363 Ark. at 505 , 215 S.W.3d at 668 .

12012–2012
United States v. Robert Bradford green
ca2 · 1956
1 sentence

2005See, e.g., Kieser v. People of New York, 56 F.3d 16 (2d Cir.1995); United States v. Costanzo, 740 F.2d 251 (3d Cir.1984); Derringer v. United States, 441 F.2d 1140 (8th Cir.1971); United States v. Bradford, 238 F.2d 395 (2d Cir.1956).

12005–2005
United States of America in No. 83-5233 v. Anthony J. Costanzo. Appeal of Anthony J. Costanzo in Nos. 82-5767, 83-5341/42 green
ca3 · 1984
1 sentence

2005See, e.g., Kieser v. People of New York, 56 F.3d 16 (2d Cir.1995); United States v. Costanzo, 740 F.2d 251 (3d Cir.1984); Derringer v. United States, 441 F.2d 1140 (8th Cir.1971); United States v. Bradford, 238 F.2d 395 (2d Cir.1956).

12005–2005
United States v. John Novak green
ca2 · 1990
2 sentences

2005Likewise, in U.S. v. Novak, 903 F.2d 883 (2d Cir. 1990), the federal appellate court followed a similar rationale in holding that representation by a lawyer who had been admitted to the bar only on the basis of false representations regarding his legal education constituted a per se Sixth Amendment violation.

2005See, e.g., Solina v. United States, 709 F.2d 160 (2d Cir.1983) (representation by person who had failed twice to pass the New York state bar examination and was not a member of any other bar was a per se violation of the right to counsel); cf. United States v. Novak, 903 F.2d 883 (2d Cir.1990) (representation by attorney who gained law license through fraud was a per se Sixth Amendment violation).

12005–2005
Parrish Cole v. United States green
ca7 · 1998
1 sentence

2005For instance, in Cole v. United States, 162 F.3d 957 (7th Cir. 1998), the Seventh Circuit Court of Appeals addressed the very question at issue here.

12005–2005
Louis A. Derringer and Gerald D. Peterson v. United States green
ca8 · 1971
1 sentence

2005See, e.g., Kieser v. People of New York, 56 F.3d 16 (2d Cir.1995); United States v. Costanzo, 740 F.2d 251 (3d Cir.1984); Derringer v. United States, 441 F.2d 1140 (8th Cir.1971); United States v. Bradford, 238 F.2d 395 (2d Cir.1956).

12005–2005
Doggett v. United States green
scotus · 1992
2 sentences

2004Id. at 655-56, 112 S.Ct. 2686 (emphasis added).

2004Id. at 655-56, 112 S.Ct. 2686 (emphasis added).

12004–2004
Massiah v. United States green
scotus · 1964
2 sentences

1994In addition, certain violations of the right to counsel may be disregarded as harmless error. [Citations omitted.] Similarly, in Massiah v. United States, 377 U.S. 201 (1964), the Court held that where a Sixth Amendment violation has occurred the defendant’s own incriminating statements could not constitutionally be used by the prosecution as evidence against him at his trial.

1994In addition, certain violations of the right to counsel may be disregarded as harmless error. [Citations omitted.] Similarly, in Massiah v. United States, 377 U.S. 201 (1964), the Court held that where a Sixth Amendment violation has occurred the defendant’s own incriminating statements could not constitutionally be used by the prosecution as evidence against him at his trial.

11994–1994
Idaho v. Wright green
scotus · 1990
2 sentences

1992Idaho v. Wright, 497 U.S. 805 , 110 S.Ct. 3139 , 111 L.Ed.2d 638 (1990); Smith v. State, supra. Killcrease did not raise the Sixth Amendment issue below.

1992Idaho v. Wright, 497 U.S. 805 , 110 S.Ct. 3139 , 111 L.Ed.2d 638 (1990); Smith v. State, supra. Killcrease did not raise the Sixth Amendment issue below.

11992–1992
State Ex Rel. Stephan v. Smith green
kan · 1987
2 sentences

1991Stephan v. Smith, 242 Kan. 336 , 747 P.2d 816 (1987), the petitioners advanced a Sixth Amendment challenge which argued that: [T]he system for appointing counsel adopted by the State violates the right to effective assistance of counsel for two reasons: (1) it creates an inherent conflict of interest between the attorney and client because the more hours an attorney spends on the case, the greater the personal cost to the attorney; and (2) it requires attorneys who are without criminal law experience or expertise to represent indigent criminal defendants.

1991Stephan v. Smith, 242 Kan. 336 , 747 P.2d 816 (1987), the petitioners advanced a Sixth Amendment challenge which argued that: [T]he system for appointing counsel adopted by the State violates the right to effective assistance of counsel for two reasons: (1) it creates an inherent conflict of interest between the attorney and client because the more hours an attorney spends on the case, the greater the personal cost to the attorney; and (2) it requires attorneys who are without criminal law experience or expertise to represent indigent criminal defendants.

11991–1991
Cuyler v. Sullivan green
scotus · 1980
2 sentences

1988Conflict and ineffective assistance The Supreme Court’s decision in Cuyler v. Sullivan, 446 U.S. 335 (1980), defined the issue which arises when a Sixth Amendment claim of ineffective assistance of counsel is based on an allegation of counsel’s conflict of interests.

1988Conflict and ineffective assistance The Supreme Court’s decision in Cuyler v. Sullivan, 446 U.S. 335 (1980), defined the issue which arises when a Sixth Amendment claim of ineffective assistance of counsel is based on an allegation of counsel’s conflict of interests.

11988–1988

Statutes the citing opinions construe

AR § Ark. Code Ann. § 10 (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 476 (1968–2026) TX 433 (1980–2026) OH 199 (1977–2026) WA 155 (1975–2026) PA 149 (1971–2026) MI 147 (1976–2025) GA 138 (1979–2026) TN 131 (1981–2026) IL 115 (1975–2026) IN 108 (1978–2026) AZ 99 (1971–2026) DC 98 (1978–2026) FL 89 (1982–2026) IA 76 (1980–2025) NJ 71 (1977–2025) MD 65 (1971–2026) NC 65 (1980–2025) DE 64 (1976–2026) OR 61 (1974–2026) AL 59 (1981–2024) CO 51 (1981–2025) WI 51 (1980–2025) VA 51 (1983–2026) CT 49 (1982–2026) MA 46 (1974–2025) MO 46 (1973–2025) KS 45 (1990–2026) NY 44 (1972–2026) MS 44 (1982–2020) LA 38 (1983–2025) MN 36 (1984–2026) NM 36 (1982–2025) UT 36 (1983–2026) OK 29 (1977–2022) ID 29 (1979–2026) KY 24 (1972–2026) ME 22 (1973–2023) MT 20 (1975–2026) WV 18 (1981–2024) RI 18 (1979–2018) NE 18 (1982–2022) SD 15 (1969–2026) HI 15 (1981–2024) NV 14 (1982–2023) AR 13 (1988–2026) WY 13 (1983–2025) SC 12 (1975–2019) AK 10 (1979–2024) ND 10 (2003–2021) VT 10 (1979–2024) VI 7 (2002–2026) GU 4 (1978–2025) NH 2 (1991–2012)

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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