Strickland v. Washington inquiry in Kentucky

13 Kentucky opinions name it 2 courts 2009–2025 9 in the last five years

The cases below were cited by Kentucky 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 (5)

Case	Followed	Cited
Bronk v. Commonwealthgreen ky · 2001 · cited in 10 Kentucky opinions naming this issue, 2009–2025 2 sentences 2025When a defendant claims that his guilty plea was involuntary, “a proper exercise of this discretion requires trial courts to consider the totality of the circumstances surrounding the guilty plea and to juxtapose the presumption of voluntariness inherent in a proper plea colloquy with a Strickland v. Washington inquiry into the performance of counsel[.]” Bronk, 58 S.W.3d at 486 (Ky. 2001) (footnotes omitted). 2023In doing so, we “juxtapose the presumption of voluntariness inherent in a proper plea colloquy with a Strickland v. Washington inquiry into the performance of counsel.” Bronk, 58 S.W.3d at 486 .	6	10
Rigdon v. Commonwealthgreen kyctapp · 2004 · cited in 2 Kentucky opinions naming this issue, 2022–2023 2 sentences 2023When a defendant argues that his guilty plea was involuntary due to ineffective assistance of counsel, the trial court must consider the totality of circumstances around the plea, and “juxtapose the presumption of voluntariness inherent in a proper plea colloquy with a Strickland v. Washington inquiry into the performance of counsel.” Rigdon, 144 S.W.3d at 288 (citing Strickland v. Washington, 466 U.S. 668 , 104 S. Ct. 2052 , 80 L. 2022Rigdon, 144 S.W.3d at 288 (footnotes omitted) (quoting Bronk v. Commonwealth, 58 S.W.3d 482, 486 (Ky. 2001) and Sparks v. Commonwealth, 721 S.W.2d 726, 727-28 (Ky.App. 1986)).	1	2
Commonwealth of Kentucky v. Douglas Rankgreen ky · 2016 · cited in 2 Kentucky opinions naming this issue, 2021–2023 2 sentences 2023Commonwealth v. Rank, 494 S.W.3d 476, 481 (Ky. 2016). 2021We must consider the totality of the circumstances surrounding the guilty plea and juxtapose the presumption of voluntariness inherent in a proper plea colloquy with a Strickland v. Washington inquiry into the performance of counsel[.] Rank, 494 S.W.3d at 481 (quoting Bronk v. Commonwealth, 58 S.W.3d 482, 486 (Ky. 2001)).	1	2
Sparks v. Commonwealthgreen kyctapp · 1986 · cited in 1 Kentucky opinions naming this issue, 2022–2022 1 sentence 2022Rigdon, 144 S.W.3d at 288 (footnotes omitted) (quoting Bronk v. Commonwealth, 58 S.W.3d 482, 486 (Ky. 2001) and Sparks v. Commonwealth, 721 S.W.2d 726, 727-28 (Ky.App. 1986)).	1	1
Commonwealth v. Thompsongreen moctapp · 2018 · cited in 1 Kentucky opinions naming this issue, 2021–2021 2 sentences 2021“The reviewing court is then obligated to consider the totality of the circumstances surrounding the guilty plea and juxtapose the presumption of voluntariness inherent in a proper plea colloquy with a Strickland v. Washington inquiry into the performance of counsel[.] The factual findings of the trial court and determinations of witness credibility are reviewed only for clear error, while the application of legal standards and precedents is reviewed de novo.” Commonwealth v. Thompson, 548 S.W.3d 881, 887 (Ky. 2018) (internal citations and quotation marks omitted). 2021“The Due Process Clause of the Fourteenth Amendment mandates that any guilty plea be made voluntarily and intelligently.” Thompson, 548 S.W.3d at 889 . “[I]t is mandatory that the defendant entering into a plea agreement have knowledge of the ‘relevant circumstances and likely consequences.’” Id. (quoting -8- Brady v. United States, 397 U.S. 742, 748 , 90 S. Ct. 1463, 1469 , 25 L.	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Kentucky. Read the followed side critically anyway.

Also cited on this issue (6)

Case	Cited	Years
Strickland v. Washington green scotus · 1984 2 sentences 2023When a defendant argues that his guilty plea was involuntary due to ineffective assistance of counsel, the trial court must consider the totality of circumstances around the plea, and “juxtapose the presumption of voluntariness inherent in a proper plea colloquy with a Strickland v. Washington inquiry into the performance of counsel.” Rigdon, 144 S.W.3d at 288 (citing Strickland v. Washington, 466 U.S. 668 , 104 S. Ct. 2052 , 80 L. 2023When a defendant argues that his guilty plea was involuntary due to ineffective assistance of counsel, the trial court must consider the totality of circumstances around the plea, and “juxtapose the presumption of voluntariness inherent in a proper plea colloquy with a Strickland v. Washington inquiry into the performance of counsel.” Rigdon, 144 S.W.3d at 288 (citing Strickland v. Washington, 466 U.S. 668 , 104 S. Ct. 2052 , 80 L.	1	2023–2023
Brady v. United States green scotus · 1970 2 sentences 2021“The Due Process Clause of the Fourteenth Amendment mandates that any guilty plea be made voluntarily and intelligently.” Thompson, 548 S.W.3d at 889 . “[I]t is mandatory that the defendant entering into a plea agreement have knowledge of the ‘relevant circumstances and likely consequences.’” Id. (quoting -8- Brady v. United States, 397 U.S. 742, 748 , 90 S. Ct. 1463, 1469 , 25 L. 2021“The Due Process Clause of the Fourteenth Amendment mandates that any guilty plea be made voluntarily and intelligently.” Thompson, 548 S.W.3d at 889 . “[I]t is mandatory that the defendant entering into a plea agreement have knowledge of the ‘relevant circumstances and likely consequences.’” Id. (quoting -8- Brady v. United States, 397 U.S. 742, 748 , 90 S. Ct. 1463, 1469 , 25 L.	1	2021–2021
McMann v. Richardson green scotus · 1970 2 sentences 2015Hill noted that “[i]n the context of guilty pleas, the first half of the Strickland v. Washington test is nothing more than a restatement of the standard of attorney competence already set forth in Tollett v. Henderson, [ 411 U.S. 258 , 93 S.Ct. 1602 , 36 L.Ed.2d 235 (1973) ], and McMann v. Richardson, [ 397 U.S. 759 , 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970)].” Hill, 474 U.S. at 58-59 , 106 S.Ct. 366 . 2015Hill noted that “[i]n the context of guilty pleas, the first half of the Strickland v. Washington test is nothing more than a restatement of the standard of attorney competence already set forth in Tollett v. Henderson, [ 411 U.S. 258 , 93 S.Ct. 1602 , 36 L.Ed.2d 235 (1973) ], and McMann v. Richardson, [ 397 U.S. 759 , 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970)].” Hill, 474 U.S. at 58-59 , 106 S.Ct. 366 .	1	2015–2015
Tollett v. Henderson green scotus · 1973 2 sentences 2015Hill noted that “[i]n the context of guilty pleas, the first half of the Strickland v. Washington test is nothing more than a restatement of the standard of attorney competence already set forth in Tollett v. Henderson, [ 411 U.S. 258 , 93 S.Ct. 1602 , 36 L.Ed.2d 235 (1973) ], and McMann v. Richardson, [ 397 U.S. 759 , 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970)].” Hill, 474 U.S. at 58-59 , 106 S.Ct. 366 . 2015Hill noted that “[i]n the context of guilty pleas, the first half of the Strickland v. Washington test is nothing more than a restatement of the standard of attorney competence already set forth in Tollett v. Henderson, [ 411 U.S. 258 , 93 S.Ct. 1602 , 36 L.Ed.2d 235 (1973) ], and McMann v. Richardson, [ 397 U.S. 759 , 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970)].” Hill, 474 U.S. at 58-59 , 106 S.Ct. 366 .	1	2015–2015
Hill v. Lockhart green scotus · 1985 2 sentences 2015Hill noted that “[i]n the context of guilty pleas, the first half of the Strickland v. Washington test is nothing more than a restatement of the standard of attorney competence already set forth in Tollett v. Henderson, [ 411 U.S. 258 , 93 S.Ct. 1602 , 36 L.Ed.2d 235 (1973) ], and McMann v. Richardson, [ 397 U.S. 759 , 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970)].” Hill, 474 U.S. at 58-59 , 106 S.Ct. 366 . 2015Hill noted that “[i]n the context of guilty pleas, the first half of the Strickland v. Washington test is nothing more than a restatement of the standard of attorney competence already set forth in Tollett v. Henderson, [ 411 U.S. 258 , 93 S.Ct. 1602 , 36 L.Ed.2d 235 (1973) ], and McMann v. Richardson, [ 397 U.S. 759 , 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970)].” Hill, 474 U.S. at 58-59 , 106 S.Ct. 366 .	1	2015–2015
Boykin v. Alabama green scotus · 1969 2 sentences 2009The trial court initially determined the voluntariness of Elza’s guilty plea during the thorough colloquy conducted pursuant to Boykin v. Alabama, 395 U.S. 238 , 89 S.Ct. 1709 , 23 L.Ed.2d 274 (1969). 2009The trial court initially determined the voluntariness of Elza’s guilty plea during the thorough colloquy conducted pursuant to Boykin v. Alabama, 395 U.S. 238 , 89 S.Ct. 1709 , 23 L.Ed.2d 274 (1969).	1	2009–2009

Statutes the citing opinions construe

KY § Ky. Rev. Stat. § 532.080 (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

TX 95 (1988–2026) AL 38 (1986–2016) GA 28 (1998–2023) MO 14 (1987–2023) KY 13 (2009–2025) IL 13 (1993–2025) NJ 11 (1994–2024) MS 9 (1987–2026) OH 9 (1998–2026) LA 8 (1986–2021) FL 7 (1988–2008) UT 7 (2001–2022) TN 7 (2001–2025) OK 7 (1988–2006) CA 5 (1992–2017) NE 5 (2017–2023) KS 3 (2002–2010) MD 3 (2001–2011) PA 2 (1987–2015) DE 2 (2024–2026) SC 2 (2009–2026) IA 2 (2014–2021) CT 2 (1997–1997) NC 2 (2006–2013) IN 2 (1994–2019) VA 2 (2017–2017) SD 2 (1987–1994)

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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