Baum standard (Indiana) · Go Syfert
← Indiana issues

Baum standard in Indiana

11 Indiana opinions name it 2 courts 1991–2019 0 in the last five years

The cases below were cited by Indiana 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 (8)

CaseFollowedCited
Hill v. Stategreen
ind · 2012 · cited in 5 Indiana opinions naming this issue, 2012–2016
2 sentences

2016Similarly, given the civil nature of probation revocation proceedings and the corresponding due process rights applicable in such proceedings, we will apply the Baum standard to Jordan’s claim of ineffective assistance of probation revocation counsel. 10 See id.; see also Hill v. State, 960 N.E.2d 141, 143 (Ind.2012) (holding that the Baum standard was the “appropriate standard” for judging the performance of counsel in a Post-Conviction Rule 2—or a belated notice of appeal—proceeding), reh’g denied. [25] Applying this “lesser” standard, we conclude that Jordan has failed to show that his prob

2016Similarly, given the civil nature of probation revocation proceedings and the corresponding due process rights applicable in such proceedings, we will apply the Baum standard to Jordan’s claim of ineffective assistance of probation revocation counsel. 10 See id.; see also Hill v. State, 960 N.E.2d 141, 143 (Ind.2012) (holding that the Baum standard was the “appropriate standard” for judging the performance of counsel in a Post-Conviction Rule 2—or a belated notice of appeal—proceeding), reh’g denied. [25] Applying this “lesser” standard, we conclude that Jordan has failed to show that his prob

25
Graves v. Stategreen
ind · 2005 · cited in 3 Indiana opinions naming this issue, 2012–2019
2 sentences

2019And in Graves, this Court described our Baker test as “something akin to the Baum standard.” 823 N.E.2d at 1196 n.4.

2019And in Graves, this Court described our Baker test as “something akin to the Baum standard.” 823 N.E.2d at 1196 n.4.

13
Strickland v. Washingtongreen
scotus · 1984 · cited in 3 Indiana opinions naming this issue, 2003–2012
2 sentences

2012The Strickland standard requires that to prevail on a claim of ineffective assistance of counsel, a defendant must show (1) the attorney’s performance was unreasonable based on prevailing professional norms and (2) “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 688, 694 . 6 2012) (reaffirming the Baum standard as the appropriate standard for evaluating post- conviction counsel’s performance).

2012The Strickland standard requires that to prevail on a claim of ineffective assistance of counsel, a defendant must show (1) the attorney’s performance was unreasonable based on prevailing professional norms and (2) “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 688, 694 . 6 2012) (reaffirming the Baum standard as the appropriate standard for evaluating post- conviction counsel’s performance).

13
Waters v. Stategreen
ind · 1991 · cited in 2 Indiana opinions naming this issue, 2001–2012
2 sentences

2012Furthermore, Reed’s performance can be easily contrasted with the post-conviction counsel’s performance in Waters, 574 N.E.2d 911 , where this Court did find a Baum violation.

2012Furthermore, Reed’s performance can be easily contrasted with the post-conviction counsel’s performance in Waters, 574 N.E.2d 911 , where this Court did find a Baum violation.

12
Matheney v. Stategreen
ind · 2005 · cited in 1 Indiana opinions naming this issue, 2012–2012
2 sentences

2012See, e.g., Matheney v. State, 834 N.E.2d 658, 661-63 (Ind.2005); Graves, 823 N.E.2d at 1197 ; Waters v. State, 574 N.E.2d 911, 912 (Ind.1991). *146 The question remains: which standard— Strickland or Baum —is appropriate for judging the performance of counsel in conjunction with P-C.R. 2 petitions and proceedings?

2012See, e.g., Matheney v. State, 834 N.E.2d 658, 661-63 (Ind.2005); Graves, 823 N.E.2d at 1197 ; Waters v. State, 574 N.E.2d 911, 912 (Ind.1991).

11
Daniels v. Stategreen
ind · 2001 · cited in 1 Indiana opinions naming this issue, 2012–2012
2 sentences

2012Daniels v. State, 741 N.E.2d 1177, 1190 (Ind.2001).

2012Daniels v. State, 741 N.E.2d 1177, 1190 (Ind.2001).

11
Poling v. Stategreen
indctapp · 2000 · cited in 1 Indiana opinions naming this issue, 2005–2005
1 sentence

2005Poling v. State, 740 N.E.2d 872, 878-79 (Ind.Ct.App.2000).

11
Baker v. Marion County Office of Family & Childrengreen
ind · 2004 · cited in 1 Indiana opinions naming this issue, 2005–2005
2 sentences

2005It focuses not on whether the lawyer might have done this or that, but whether "the parents received a fundamentally fair trial whose facts demonstrate an accurate determination." Baker v. Marion County Office of Family and Children, 810 N.E.2d 1035, 1041 (Ind.2004).

2005It focuses not on whether the lawyer might have done this or that, but whether "the parents received a fundamentally fair trial whose facts demonstrate an accurate determination." Baker v. Marion County Office of Family and Children, 810 N.E.2d 1035, 1041 (Ind.2004).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Baum v. State green
ind · 1989
2 sentences

2014Id.

2012Emerson did not provide evidence showing anything other than the fact that Emerson’s counsel “in fact appeared and represented the petitioner in a procedurally fair setting which resulted in a judgment of the court.” Baum, 533 N.E.2d at 1201 .

22012–2014
Mark L. Jordan v. State of Indiana green
indctapp · 2013
2 sentences

2014We also observe that the Court in Hill stated that the Baum standard is highly deferential and a 3 Canenguez-Ramirez relies upon Jordan v. State, 988 N.E.2d 394 (Ind. Ct. App. 2013), for the proposition that he could not be at fault for failing to file a timely notice of appeal.

2014We also observe that the Court in Hill stated that the Baum standard is highly deferential and a 3 Canenguez-Ramirez relies upon Jordan v. State, 988 N.E.2d 394 (Ind. Ct. App. 2013), for the proposition that he could not be at fault for failing to file a timely notice of appeal.

12014–2014
Patton v. State green
indctapp · 1989
2 sentences

2001We do not believe this was a ‘procedurally fair setting' because, in essence, the court had no record before it from which it could review Patton’s claim.” Patton, 537 N.E.2d at 519-20 .

2001We do not believe this was a ‘procedurally fair setting' because, in essence, the court had no record before it from which it could review Patton’s claim.” Patton, 537 N.E.2d at 519-20 .

12001–2001
Evans v. State green
ind · 1986
2 sentences

1991Without deciding the issue, we determine that appellate counsel's performance was effective even under the more stringent Strickland standard. [2] We note that in Evans v. State (1986), Ind., 497 N.E.2d 919 , 923-24 the court acknowledged that the statutory factor concerning the depreciating effect of imposing a reduced sentence has apparent application only when the court is considering imposing a reduced sentence.

1991Without deciding the issue, we determine that appellate counsel's performance was effective even under the more stringent Strickland standard. [2] We note that in Evans v. State (1986), Ind., 497 N.E.2d 919 , 923-24 the court acknowledged that the statutory factor concerning the depreciating effect of imposing a reduced sentence has apparent application only when the court is considering imposing a reduced sentence.

11991–1991

Where else courts name it

IN 11 (1991–2019) NJ 4 (1987–2025) NY 2 (2018–2020)

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.

← Caselaw search · G Cite Topics · Brief Check