Ibarra standard (California) · Go Syfert
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Ibarra standard in California

11 California opinions name it 2 courts 1970–2021 1 in the last five years

The cases below were cited by California 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 (10)

CaseFollowedCited
People v. Ibarragreen
cal · 1963 · cited in 3 California opinions naming this issue, 1970–1975
2 sentences

1975(People v. Ibarra (1963) 60 Cal.2d 460, 464 [ 34 Cal.Rptr. 863 , 386 P.2d 487 ].) We have examined the instances to which defendant has referred and conclude that while counsel’s actions were at times not exemplary they were not sufficiently egregious to warrant reversal under the Ibarra rule.

1975(People v. Ibarra (1963) 60 Cal.2d 460, 464 [ 34 Cal.Rptr. 863 , 386 P.2d 487 ].) We have examined the instances to which defendant has referred and conclude that while counsel’s actions were at times not exemplary they were not sufficiently egregious to warrant reversal under the Ibarra rule.

23
People v. Popegreen
cal · 1979 · cited in 2 California opinions naming this issue, 1979–1981
2 sentences

1981In People v. Pope (1979) 23 Cal.3d 412 [ 152 Cal.Rptr. 732 , 590 P.2d 859 ], a history of the evaporation of the Ibarra standard (i.e., farce and sham) was set forth, with the court adopting a standard similar to one set out in United States v. De Coster (D.C.Cir. 1973) 487 F.2d 1197 .

1981In People v. Pope (1979) 23 Cal.3d 412 [ 152 Cal.Rptr. 732 , 590 P.2d 859 ], a history of the evaporation of the Ibarra standard (i.e., farce and sham) was set forth, with the court adopting a standard similar to one set out in United States v. De Coster (D.C.Cir. 1973) 487 F.2d 1197 .

12
Palma v. U.S. Industrial Fasteners, Inc.green
cal · 1984 · cited in 1 California opinions naming this issue, 1984–1984
2 sentences

1984(Palma v. U.S. Industrial Fasteners, Inc. (1984) 36 Cal.3d 171, 180 [ 203 Cal.Rptr. 626 , 681 P.2d 893 ].) Let a peremptory writ of mandate issue directing the municipal court to conduct a hearing on Ibarra’s motion to dismiss consistent with this opinion.

1984(Palma v. U.S. Industrial Fasteners, Inc. (1984) 36 Cal.3d 171, 180 [ 203 Cal.Rptr. 626 , 681 P.2d 893 ].) Let a peremptory writ of mandate issue directing the municipal court to conduct a hearing on Ibarra’s motion to dismiss consistent with this opinion.

11
People v. Cookgreen
cal · 1975 · cited in 1 California opinions naming this issue, 1979–1979
2 sentences

1979For example, it stated: “In several cases, this court has moved away from the ‘farce or sham’ standard,” and “[i]nsofar as it survives, the ‘farce or sham’ standard . . . has been widely criticized. . . .” (23 Cal.3d at pp. 421-422.) 5 In People v. Cook (1975) 13 Cal.3d 663, 671, 672 [ 119 Cal.Rptr. 500 , 532 P.2d 148 ], our Supreme Court knowingly applied the Ibarra standard of constitutionally adequate representation to privately retained counsel. 6 If it is clear to a reviewing court that trial counsel intentionally represented his client in an incompetent manner in order to obtain a revers

1979For example, it stated: “In several cases, this court has moved away from the ‘farce or sham’ standard,” and “[i]nsofar as it survives, the ‘farce or sham’ standard . . . has been widely criticized. . . .” (23 Cal.3d at pp. 421-422.) 5 In People v. Cook (1975) 13 Cal.3d 663, 671, 672 [ 119 Cal.Rptr. 500 , 532 P.2d 148 ], our Supreme Court knowingly applied the Ibarra standard of constitutionally adequate representation to privately retained counsel. 6 If it is clear to a reviewing court that trial counsel intentionally represented his client in an incompetent manner in order to obtain a revers

11
People v. Rodriguezgreen
calctapp · 1977 · cited in 1 California opinions naming this issue, 1979–1979
2 sentences

1979It is the failure to have an appropriate adjudication of a defense that reduces the trial to a ‘farce or a sham,” and which thus renders a defendant’s trial fundamentally unfair—in violation of the constitutional due process rights guaranteed to a defendant.” (People v. Rodriguez (1977) 73 Cal.App.3d 1023, 1028 [ 141 Cal.Rptr. 118 ].) (Latter italics in original.) In People v. Pope (1979) 23 Cal.3d 412 [ 152 Cal.Rptr. 732 , 590 P.2d 859 ], our high court discarded the Ibarra standard for ineffective assistance of counsel and declared that “a conviction may not be upheld if the state has furnis

1979It is the failure to have an appropriate adjudication of a defense that reduces the trial to a ‘farce or a sham,” and which thus renders a defendant’s trial fundamentally unfair—in violation of the constitutional due process rights guaranteed to a defendant.” (People v. Rodriguez (1977) 73 Cal.App.3d 1023, 1028 [ 141 Cal.Rptr. 118 ].) (Latter italics in original.) In People v. Pope (1979) 23 Cal.3d 412 [ 152 Cal.Rptr. 732 , 590 P.2d 859 ], our high court discarded the Ibarra standard for ineffective assistance of counsel and declared that “a conviction may not be upheld if the state has furnis

11
Cabell v. Julius B.green
calctapp · 1977 · cited in 1 California opinions naming this issue, 1979–1979
2 sentences

1979For example, it stated: “In several cases, this court has moved away from the ‘farce or sham’ standard,” and “[i]nsofar as it survives, the ‘farce or sham’ standard . . . has been widely criticized. . . .” (23 Cal.3d at pp. 421-422.) 5 In People v. Cook (1975) 13 Cal.3d 663, 671, 672 [ 119 Cal.Rptr. 500 , 532 P.2d 148 ], our Supreme Court knowingly applied the Ibarra standard of constitutionally adequate representation to privately retained counsel. 6 If it is clear to a reviewing court that trial counsel intentionally represented his client in an incompetent manner in order to obtain a revers

1979For example, it stated: “In several cases, this court has moved away from the ‘farce or sham’ standard,” and “[i]nsofar as it survives, the ‘farce or sham’ standard . . . has been widely criticized. . . .” (23 Cal.3d at pp. 421-422.) 5 In People v. Cook (1975) 13 Cal.3d 663, 671, 672 [ 119 Cal.Rptr. 500 , 532 P.2d 148 ], our Supreme Court knowingly applied the Ibarra standard of constitutionally adequate representation to privately retained counsel. 6 If it is clear to a reviewing court that trial counsel intentionally represented his client in an incompetent manner in order to obtain a revers

11
People v. Williamsgreen
cal · 1970 · cited in 1 California opinions naming this issue, 1977–1977
2 sentences

1977(People v. Williams, supra, 2 Cal.3d 894, 906.) We therefore conclude that the duty of trial court inquiiy into the reasons why a defendant seeks to discharge counsel applies only when the defendant asserts directly or by implication that his counsel’s performance has been so inadequate as to deny him his constitutional right to effective counsel.

1977(People v. Williams, supra, 2 Cal.3d 894, 906.) We therefore conclude that the duty of trial court inquiiy into the reasons why a defendant seeks to discharge counsel applies only when the defendant asserts directly or by implication that his counsel’s performance has been so inadequate as to deny him his constitutional right to effective counsel.

11
In Re Mosleygreen
cal · 1970 · cited in 1 California opinions naming this issue, 1976–1976
2 sentences

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

11
People v. Floydgreen
cal · 1970 · cited in 1 California opinions naming this issue, 1976–1976
2 sentences

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

11
People v. Pijalgreen
calctapp · 1973 · cited in 1 California opinions naming this issue, 1975–1975
2 sentences

1975While the Attorney General is entirely correct in his contention (see People v. Pijal, 33 Cal.App.3d 682, 692 [ 109 Cal.Rptr. 230 ]), we elect to dispose of the entrapment question on its merits because of the ever-present Ibarra doctrine.

1975While the Attorney General is entirely correct in his contention (see People v. Pijal, 33 Cal.App.3d 682, 692 [ 109 Cal.Rptr. 230 ]), we elect to dispose of the entrapment question on its merits because of the ever-present Ibarra doctrine.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (11)

CaseCitedYears
In Re Ibarra green
cal · 1983
2 sentences

2021The court should be satisfied that the prosecution has not misrepresented facts to the defendant, and that the substance of the inducement is within the proper scope of the prosecutor’s business.” ( Ibarra, supra, 34 Cal.3d at pp. 288–289.) If the People are 9. leveraging their ability to prosecute third parties, they must have “a reasonable and good faith case against the third parties to whom leniency is promised.” (Id. at p. 289.) The trial court discussed the Ibarra factors at length during the motion hearing.

2021The court should be satisfied that the prosecution has not misrepresented facts to the defendant, and that the substance of the inducement is within the proper scope of the prosecutor’s business.” ( Ibarra, supra, 34 Cal.3d at pp. 288–289.) If the People are 9. leveraging their ability to prosecute third parties, they must have “a reasonable and good faith case against the third parties to whom leniency is promised.” (Id. at p. 289.) The trial court discussed the Ibarra factors at length during the motion hearing.

12021–2021
People v. Navarrete green
calctapp · 2010
1 sentence

2014This case is unlike People v. Navarrete (2010) 181 Cal.App.4th 828, 831-832 , in which a mistrial was required after a detective deliberately suggested to the jury that the defendant confessed and the court ruled that "defendant's statement is inadmissible." (Id. at p. 831.) Cumulative Error We reject Ibarra’s claim of cumulative error.

12014–2014
Overby v. Municipal Court green
calctapp · 1981
1 sentence

1984(Overby v. Municipal Court, supra, 121 Cal.App.3d 377 ; People v. Lawson (1979) 94 Cal.App.3d 194 [ 156 Cal.Rptr. 226 ]; People v. Vanderburg, supra, 32 Cal.App.3d 526 .) At the hearing on Ibarra’s motion to dismiss, he offered his declaration as proof of prejudice.

11984–1984
People v. Lawson green
calctapp · 1979
2 sentences

1984(Overby v. Municipal Court, supra, 121 Cal.App.3d 377 ; People v. Lawson (1979) 94 Cal.App.3d 194 [ 156 Cal.Rptr. 226 ]; People v. Vanderburg, supra, 32 Cal.App.3d 526 .) At the hearing on Ibarra’s motion to dismiss, he offered his declaration as proof of prejudice.

1984(Overby v. Municipal Court, supra, 121 Cal.App.3d 377 ; People v. Lawson (1979) 94 Cal.App.3d 194 [ 156 Cal.Rptr. 226 ]; People v. Vanderburg, supra, 32 Cal.App.3d 526 .) At the hearing on Ibarra’s motion to dismiss, he offered his declaration as proof of prejudice.

11984–1984
Dillingham v. United States green
scotus · 1975
2 sentences

1984Sonenshine, J., and Crosby, J., concurred. 1 Ibarra’s reliance on Dillingham v. United States (1975) 423 U.S. 64 [ 46 L.Ed.2d 205 , 96 S.Ct. 303 ] is misplaced.

1984Sonenshine, J., and Crosby, J., concurred. 1 Ibarra’s reliance on Dillingham v. United States (1975) 423 U.S. 64 [ 46 L.Ed.2d 205 , 96 S.Ct. 303 ] is misplaced.

11984–1984
People v. Vanderburg green
calctapp · 1973
1 sentence

1984(Overby v. Municipal Court, supra, 121 Cal.App.3d 377 ; People v. Lawson (1979) 94 Cal.App.3d 194 [ 156 Cal.Rptr. 226 ]; People v. Vanderburg, supra, 32 Cal.App.3d 526 .) At the hearing on Ibarra’s motion to dismiss, he offered his declaration as proof of prejudice.

11984–1984
United States v. Willie Decoster, Jr. green
cadc · 1973
1 sentence

1981In People v. Pope (1979) 23 Cal.3d 412 [ 152 Cal.Rptr. 732 , 590 P.2d 859 ], a history of the evaporation of the Ibarra standard (i.e., farce and sham) was set forth, with the court adopting a standard similar to one set out in United States v. De Coster (D.C.Cir. 1973) 487 F.2d 1197 .

11981–1981
Bellomy v. Union Concrete Pipe Co. green
scotus · 1970
1 sentence

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

11976–1976
Campbell v. California Department of Corrections green
scotus · 1970
1 sentence

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

11976–1976
King v. California neutral
scotus · 1972
1 sentence

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

11976–1976
Mabry v. California green
scotus · 1972
1 sentence

1976(In re Mosley, 1 Cal.3d 913, 924 [ 83 Cal.Rptr. 809 , 464 P.2d 473 ], cert. den., 400 U.S. 905 [ 27 L.Ed.2d 142 , 91 S.Ct. 144 ]; People v. Floyd, 1 Cal.3d 694, 709 [ 83 Cal.Rptr. 608 , 464 P.2d 64 ], cert. den., 406 U.S. 972 [ 32 L.Ed.2d 672 , 92 S.Ct. 2418 ].) Furthermore, a mere sociopathic personality with schizoid tendencies is insufficient without more to authorize an instruction on diminished capacity.

11976–1976

Statutes the citing opinions construe

CA § Cal. Penal Code § 187 (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 11 (1970–2021) TX 4 (2007–2019) KS 2 (2018–2021)

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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