second element test (Utah) · Go Syfert
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second element test in Utah

13 Utah opinions name it 2 courts 2000–2024 6 in the last five years

The cases below were cited by Utah 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 (6)

CaseFollowedCited
Strickland v. Washingtongreen
scotus · 1984 · cited in 3 Utah opinions naming this issue, 2021–2024
2 sentences

2024The second element of the test “requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.” Id. at 687 .

2024Hughes’s ineffective assistance claim fails the second element of the test. ¶46 Under the second element of the ineffective assistance of counsel test, the appellant must show that defense counsel’s deficient performance prejudiced the defense by “depriv[ing] the 20220640-CA 18 2024 UT App 168 State v. Hughes defendant of a fair trial, a trial whose result is reliable.” Strickland, 466 U.S. at 687 .

13
MacK v. Utah State Department of Commercegreen
utah · 2009 · cited in 2 Utah opinions naming this issue, 2024–2024
2 sentences

2024See Mack, 2009 UT 47, ¶ 30 .

2024Id. (quotation simplified). ¶28 In assessing that element, Utah courts apply the transactional test found in section 24 of the Restatement (Second) of Judgments.

12
State v. Millergreen
utahctapp · 2023 · cited in 1 Utah opinions naming this issue, 2024–2024
1 sentence

2024“A defendant’s inability to establish either element defeats a claim for ineffective assistance of counsel.” Miller, 2023 UT App 85, ¶ 25 (cleaned up).

11
Van Leeuwen v. Bank of America NAgreen
utahctapp · 2016 · cited in 1 Utah opinions naming this issue, 2020–2020
1 sentence

2020See Van Leeuwen, 2016 UT App 212, ¶ 8 .

11
MacRis & Associates, Inc. v. Neways, Inc.green
utahctapp · 1999 · cited in 1 Utah opinions naming this issue, 2000–2000
1 sentence

2000See Madsen, 769 P.2d at 247 . 21 In reference to the second element of the test outlined above, Neways argued before the court of appeals that Maecris's claims for fraudulent transfer, successor Hability, and alter ego "should have been raised" in Maeris I because Macris knew of its claims against Neways before the trial in Macris I began and should therefore have amended its complaint in that action and asserted the claims now pursued in the present action. 122 The court of appeals rejected Neways's argument and held that the doctrine of claim preclusion did not require Ma-cris to litigate it

11
Madsen v. Borthickgreen
utah · 1988 · cited in 1 Utah opinions naming this issue, 2000–2000
1 sentence

2000See Madsen, 769 P.2d at 247 . 21 In reference to the second element of the test outlined above, Neways argued before the court of appeals that Maecris's claims for fraudulent transfer, successor Hability, and alter ego "should have been raised" in Maeris I because Macris knew of its claims against Neways before the trial in Macris I began and should therefore have amended its complaint in that action and asserted the claims now pursued in the present action. 122 The court of appeals rejected Neways's argument and held that the doctrine of claim preclusion did not require Ma-cris to litigate it

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
State v. Scott green
utah · 2020
2 sentences

2021Under the second, a defendant must show “that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.” Id. at 687 . ¶27 To satisfy the second element of the inquiry, “[i]t is not enough for the defendant to show that the errors had some conceivable effect on the outcome of the proceeding.” Id. at 693 . 20190360-CA 9 2021 UT App 75 State v. Moore Rather, “consider[ing] the totality of the evidence before the judge or jury,” id. at 695, a defendant must “demonstrate a reasonable probability that the outcome of his or her case would have bee

2021Under the second, a defendant must show “that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.” Id. at 687 . ¶27 To satisfy the second element of the inquiry, “[i]t is not enough for the defendant to show that the errors had some conceivable effect on the outcome of the proceeding.” Id. at 693 . 20190360-CA 9 2021 UT App 75 State v. Moore Rather, “consider[ing] the totality of the evidence before the judge or jury,” id. at 695, a defendant must “demonstrate a reasonable probability that the outcome of his or her case would have bee

22021–2024
Snyder v. Murray City Corp. green
utah · 2003
2 sentences

2011Id. ¶ 29 (quoting Collins v. Sandy City Bd. of Adjustment, 2002 UT 77, ¶ 12 , 52 P.3d 1267 ). $42 To satisfy the second element of this test, the issue to be litigated must be "identical" in both cases.

2011Id. ¶ 29 (quoting Collins v. Sandy City Bd. of Adjustment, 2002 UT 77, ¶ 12 , 52 P.3d 1267 ). ¶42 To satisfy the second element of this test, the issue to be litigated must be "identical" in both cases.

22011–2011
Collins v. Sandy City Board of Adjustment green
utah · 2002
2 sentences

2011Id. ¶ 29 (quoting Collins v. Sandy City Bd. of Adjustment, 2002 UT 77, ¶ 12 , 52 P.3d 1267 ). $42 To satisfy the second element of this test, the issue to be litigated must be "identical" in both cases.

2011Id. ¶ 29 (quoting Collins v. Sandy City Bd. of Adjustment, 2002 UT 77, ¶ 12 , 52 P.3d 1267 ). $42 To satisfy the second element of this test, the issue to be litigated must be "identical" in both cases.

22011–2011
Ward v. McGarry green
utahctapp · 2024
1 sentence

2024Hughes’s ineffective assistance claim fails the second element of the test. ¶46 Under the second element of the ineffective assistance of counsel test, the appellant must show that defense counsel’s deficient performance prejudiced the defense by “depriv[ing] the 20220640-CA 18 2024 UT App 168 State v. Hughes defendant of a fair trial, a trial whose result is reliable.” Strickland, 466 U.S. at 687 .

12024–2024
Honnen Equipment v. DAZ Management green
utah · 2022
2 sentences

2022Co., 2022 UT 15 , ¶ 29 n.26, 508 P.3d 84 (cleaned up).

2022Co., 2022 UT 15 , ¶ 29 n.26, 508 P.3d 84 (cleaned up).

12022–2022
State v. Moore green
utahctapp · 2021
1 sentence

2021Under the second, a defendant must show “that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.” Id. at 687 . ¶27 To satisfy the second element of the inquiry, “[i]t is not enough for the defendant to show that the errors had some conceivable effect on the outcome of the proceeding.” Id. at 693 . 20190360-CA 9 2021 UT App 75 State v. Moore Rather, “consider[ing] the totality of the evidence before the judge or jury,” id. at 695, a defendant must “demonstrate a reasonable probability that the outcome of his or her case would have bee

12021–2021
Gillmor v. Family Link, LLC green
utah · 2012
1 sentence

2019Gillmor v. Family Link, LLC, 2012 UT 38, 6 .

12019–2019
Overstock. Com, Inc. v. SmartBargains, Inc. green
utah · 2008
2 sentences

2013Overstock. com, Inc. v. Smart- *274 Bargains, Inc., 2008 UT 55, ¶ 18 , 192 P.3d 858 .

2013Overstock. com, Inc. v. Smart- *274 Bargains, Inc., 2008 UT 55, ¶ 18 , 192 P.3d 858 .

12013–2013
Allen v. Ortez green
utah · 1990
1 sentence

2001The rule enunciated in Wright is thus congruent with the second element of the test set forth in Ortes, that the allegedly defamatory statements "have some reference to the subject matter of the proceeding." In Ortez, this court enunciated the three-part rule in use today because "[nJeither in Wright nor in Beesley did we have occasion to elaborate on *900 the elements of the cause of action." 802 P.2d at 1312 .

12001–2001
DeBry v. Godbe green
utah · 1999
2 sentences

2001It has "some reference to the subject matter of the proceeding." As we have said previously, in order to satisfy the second part of the judicial proceeding privilege, "[a] statement need not be relevant or pertinent to the judicial proceeding from an evidentiary point of view for the privilege to apply." DeBry, 1999 UT 111 at ¶ 16 , 992 P.2d 979 ; see also Keeton et al., supra at 817-18 .

2001It has "some reference to the subject matter of the proceeding." As we have said previously, in order to satisfy the second part of the judicial proceeding privilege, "[a] statement need not be relevant or pertinent to the judicial proceeding from an evidentiary point of view for the privilege to apply." DeBry, 1999 UT 111 at ¶ 16 , 992 P.2d 979 ; see also Keeton et al., supra at 817-18 .

12001–2001

Where else courts name it

NC 65 (1995–2019) OH 55 (1983–2026) CA 38 (1957–2026) TX 33 (1961–2025) IL 21 (1989–2026) UT 13 (2000–2024) WI 12 (1980–2024) NM 11 (2004–2024) NY 11 (1976–2026) ID 11 (1966–2021) WY 9 (1992–2016) WA 9 (1992–2024) MI 8 (1972–2023) GA 7 (1993–2018) MA 7 (2000–2021) IA 6 (1980–2023) RI 6 (1980–2013) MO 6 (1992–2014) IN 6 (1982–2025) PA 6 (1982–2022) DE 5 (1975–2025) MD 5 (1994–2019) VA 5 (1989–2023) CT 4 (2002–2025) TN 4 (1954–2007) DC 4 (1981–2025) CO 3 (1983–2024) AL 3 (1980–2024) OR 3 (1985–2026) NJ 3 (2010–2021) AZ 3 (2006–2017) ME 2 (2005–2021) FL 2 (1984–2000) SD 2 (1986–2025) LA 2 (2006–2016) ND 2 (1982–2000) HI 2 (1995–1995)

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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