Strickland two-prong test in Idaho

2023“This Court employs the Strickland two-prong test to determine whether a defendant in a criminal case received effective assistance of counsel.” Thumm v. State, 165 Idaho 405 , 412–13, 447 P.3d 853 , 860–61 (2019) (citing Strickland v. Washington, 466 U.S. 668 (1984)).

2017The Idaho Supreme Court “has adopted the Strickland two-prong test to evaluate whether a criminal defendant received effective assistance of counsel.” Dunlap v. State, 141 Idaho 50, 59 , 106 P.3d 376, 385 (2004); Strickland v. Washington, 466 U.S. 668 (1984).

2017The Idaho Supreme Court “has adopted the Strickland two-prong test to evaluate whether a criminal defendant received effective assistance of counsel.” Dunlap v. State, 141 Idaho 50, 59 , 106 P.3d 376, 385 (2004); Strickland v. Washington, 466 U.S. 668 (1984).

2017The Idaho Supreme Court “has adopted the Strickland two-prong test to evaluate whether a criminal defendant received effective assistance of counsel.” Dunlap v. State, 141 Idaho 50, 59 , 106 P.3d 376, 385 (2004); Strickland v. Washington, 466 U.S. 668 (1984).

2015Under the Strickland two-prong test, the defendant must show: (1) that trial “counsel’s performance was deficient;” and (2) that “the deficient performance prejudiced the defense.” Strickland v. Washington, 466 U.S. 668, 687 (1984); see Dunlap V, 155 Idaho 345, 383, 313 P.3d 1, 39 (2013). “[T]he performance inquiry must be whether counsel’s assistance was reasonable considering all the circumstances.” Strickland, 466 U.S. at 688.

2015Under the Strickland two-prong test, the defendant must show: (1) that trial “counsel’s performance was deficient;” and (2) that “the deficient performance prejudiced the defense.” Strickland v. Washington, 466 U.S. 668, 687 (1984); see Dunlap V, 155 Idaho 345, 383, 313 P.3d 1, 39 (2013). “[T]he performance inquiry must be whether counsel’s assistance was reasonable considering all the circumstances.” Strickland, 466 U.S. at 688.

2013This Court has “adopted the Strickland two-prong test to evaluate whether a criminal defendant received effective assistance of counsel.” Dunlap III, 141 Idaho 50, 59 , 106 P.3d 376, 385 (2004) (citing Strickland v. Washington, 466 U.S. 668, 687 (1984); State v. Mathews, 133 Idaho 300, 306 , 986 P.2d 323, 329 (1999)).

2013This Court has “adopted the Strickland two-prong test to evaluate whether a criminal defendant received effective assistance of counsel.” Dunlap III, 141 Idaho 50, 59 , 106 P.3d 376, 385 (2004) (citing Strickland v. Washington, 466 U.S. 668, 687 (1984); State v. Mathews, 133 Idaho 300, 306 , 986 P.2d 323, 329 (1999)).

2015This Court “will not second-guess trial counsel’s strategic and tactical choices . . . and we presume trial counsel was competent and that trial tactics were based on sound legal strategy.” State v. Porter, 130 Idaho 772, 792, 948 P.2d 127, 147 (1997). 47 “Voir dire plays a critical function in assuring the criminal defendant that his Sixth Amendment right to an impartial jury will be honored.” Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981).

2015This Court “will not second-guess trial counsel’s strategic and tactical choices . . . and we presume trial counsel was competent and that trial tactics were based on sound legal strategy.” State v. Porter, 130 Idaho 772, 792, 948 P.2d 127, 147 (1997). 47 “Voir dire plays a critical function in assuring the criminal defendant that his Sixth Amendment right to an impartial jury will be honored.” Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981).

2015See Moormann v. Ryan, 628 F.3d 1102, 1106-07 (9th Cir.2010); State v. Sellers, 290 Neb. 18 , 858 N.W.2d 577 , 585 (2015); Wright v. State, 765 N.W.2d 85, 91 (Minn.2009).

2015See Moormann v. Ryan, 628 F.3d 1102, 1106–07 (9th Cir. 2010); State v. Sellers, 858 N.W.2d 577, 585 (Neb. 2015); Wright v. State, 765 N.W.2d 85, 91 (Minn. 2009).

2015See Moormann v. Ryan, 628 F.3d 1102, 1106-07 (9th Cir.2010); State v. Sellers, 290 Neb. 18 , 858 N.W.2d 577 , 585 (2015); Wright v. State, 765 N.W.2d 85, 91 (Minn.2009).

2015See Moormann v. Ryan, 628 F.3d 1102, 1106–07 (9th Cir. 2010); State v. Sellers, 858 N.W.2d 577, 585 (Neb. 2015); Wright v. State, 765 N.W.2d 85, 91 (Minn. 2009).

2013In order to survive a motion for summary dismissal, post-conviction relief claims based upon ineffective assistance of counsel must establish “the existence of material issues of fact as to whether: (1) counsel’s performance was deficient, and (2) that deficiency prejudiced appellant’s case.” Kelly v. State, 149 Idaho 517, 522 , 236 P.3d 1277, 1282 (2010) (citing Saykhamchone, 127 Idaho at 323 , 900 P.2d at 799 ).

2013In order to survive a motion for summary dismissal, post-conviction relief claims based upon ineffective assistance of counsel must establish “the existence of material issues of fact as to whether: (1) counsel’s performance was deficient, and (2) that deficiency prejudiced appellant’s case.” Kelly v. State, 149 Idaho 517, 522 , 236 P.3d 1277, 1282 (2010) (citing Saykhamchone, 127 Idaho at 323 , 900 P.2d at 799 ).

2025“This Court employs the Strickland two-prong test to determine whether a defendant in a criminal case received effective assistance of counsel.” Rodriquez v. State, 171 Idaho 634, 645 , 524 P.3d 913, 924 (2023).

2025“This Court employs the Strickland two-prong test to determine whether a defendant in a criminal case received effective assistance of counsel.” Rodriquez v. State, 171 Idaho 634, 645 , 524 P.3d 913, 924 (2023).

2025Under Strickland v. Washington, 466 U.S. 668, 669 (1984), “an applicant for post-conviction relief must demonstrate: (1) counsel’s performance fell below an objective standard of reasonableness; and (2) there is a reasonable probability that, but for counsel’s errors, the outcome would have been different.” “To establish prejudice resulting from his or her attorney’s performance, a defendant must show that as a result of counsel’s deficient performance there is a reasonable probability that, but for counsel’s errors, he would not have [pleaded] guilty and would have insisted on going to trial.

2025Under Strickland v. Washington, 466 U.S. 668, 669 (1984), “an applicant for post-conviction relief must demonstrate: (1) counsel’s performance fell below an objective standard of reasonableness; and (2) there is a reasonable probability that, but for counsel’s errors, the outcome would have been different.” “To establish prejudice resulting from his or her attorney’s performance, a defendant must show that as a result of counsel’s deficient performance there is a reasonable probability that, but for counsel’s errors, he would not have [pleaded] guilty and would have insisted on going to trial.

2019Mitchell v. State, 132 Idaho 274, 277 , 971 P.2d 727, 730 (1998) (referencing Strickland v. Washington, 466 U.S. 668 (1984)).

2019Mitchell v. State, 132 Idaho 274, 277 , 971 P.2d 727, 730 (1998) (referencing Strickland v. Washington, 466 U.S. 668 (1984)).

2015This Court “will not second-guess trial counsel’s strategic and tactical choices . . . and we presume trial counsel was competent and that trial tactics were based on sound legal strategy.” State v. Porter, 130 Idaho 772, 792, 948 P.2d 127, 147 (1997). 47 “Voir dire plays a critical function in assuring the criminal defendant that his Sixth Amendment right to an impartial jury will be honored.” Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981).

2004Mathews, 133 Idaho at 306 , 986 P.2d at 329 ; Wood, 132 Idaho at 95 , 967 P.2d at 709 ; Giles v. State, 125 Idaho 921, 924 , 877 P.2d 365, 368 (1994).

2004Mathews, 133 Idaho at 306 , 986 P.2d at 329 ; Wood, 132 Idaho at 95 , 967 P.2d at 709 ; Giles v. State, 125 Idaho 921, 924 , 877 P.2d 365, 368 (1994).