Strickland two-prong test (New Jersey) · Go Syfert
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Strickland two-prong test in New Jersey

79 New Jersey opinions name it 2 courts 1999–2026 73 in the last five years

The cases below were cited by New Jersey 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 (7)

CaseFollowedCited
State v. Fritzgreen
nj · 1987 · cited in 67 New Jersey opinions naming this issue, 1999–2026
2 sentences

2026To establish a prima facie claim for ineffective assistance of counsel, a defendant must satisfy the two-prong test established in Strickland. 466 U.S. at 687 ; see also State v. Fritz, 105 N.J. 42, 58 (1987) (adopting the Strickland two- prong test in New Jersey).

2026VI); see also State v. Fritz, 105 N.J. 42, 58 (1987) (adopting the Strickland two-prong test in New Jersey); State v. Gideon, 244 N.J. 538 , 550-51 (2021) (describing the two required prongs under Strickland).

6667
Strickland v. Washingtongreen
scotus · 1984 · cited in 52 New Jersey opinions naming this issue, 2023–2026
2 sentences

2026To establish a prima facie claim for ineffective assistance of counsel, a defendant must satisfy the two-prong test established in Strickland. 466 U.S. at 687 ; see also State v. Fritz, 105 N.J. 42, 58 (1987) (adopting the Strickland two- prong test in New Jersey).

2026See Strickland v. Washington, 466 U.S. 668 , 687 A-1124-24 4 (1984) (explaining that to establish a claim of ineffective assistance of counsel, a defendant must show (1) "counsel made errors so serious that counsel was not functioning as the 'counsel' guaranteed the defendant by the Sixth Amendment[,]" and (2) "the deficient performance prejudiced the defense" ); State v. Fritz, 105 N.J. 42, 58 (1987) (adopting the Strickland two-prong test in New Jersey).

3352
In Re Contest of November 8, 2011 General Election of Office of New Jersey General Assembly, Fourth Legislative Districtgreen
nj · 2012 · cited in 4 New Jersey opinions naming this issue, 2018–2025
2 sentences

2025To demonstrate "prejudice after having entered a guilty plea, a defendant must prove 'that there is a reasonable probability that, but for counsel's errors, [he or she] would not have pled guilty and would have insisted on going to trial.'" State v. Gaitan, 209 N.J. 339, 351 (2012) (quoting State v. Nuñez-Valdéz, 200 N.J. 129 , 139 (2009)).

2019In the context of a PCR petition challenging a guilty plea, the second prong is satisfied when a defendant A-2948-17T2 10 establishes "that there is a reasonable probability that, but for counsel's errors [he or she] would not have pled guilty and would have insisted on going to trial." Gaitan, 209 N.J. at 351 (alteration in original) (quoting State v. Nunez-Valdez, 200 N.J. 129 , 139 (2009)).

44
State v. Nunez-Valdezgreen
nj · 2009 · cited in 4 New Jersey opinions naming this issue, 2018–2025
2 sentences

2025To demonstrate "prejudice after having entered a guilty plea, a defendant must prove 'that there is a reasonable probability that, but for counsel's errors, [he or she] would not have pled guilty and would have insisted on going to trial.'" State v. Gaitan, 209 N.J. 339, 351 (2012) (quoting State v. Nuñez-Valdéz, 200 N.J. 129 , 139 (2009)).

2019In the context of a PCR petition challenging a guilty plea, the second prong is satisfied when a defendant A-2948-17T2 10 establishes "that there is a reasonable probability that, but for counsel's errors [he or she] would not have pled guilty and would have insisted on going to trial." Gaitan, 209 N.J. at 351 (alteration in original) (quoting State v. Nunez-Valdez, 200 N.J. 129 , 139 (2009)).

24
State v. Gaithergreen
njsuperctappdiv · 2007 · cited in 2 New Jersey opinions naming this issue, 2019–2022
2 sentences

2022State v. Gaither, 396 N.J.

2019State v. A-3841-17T1 13 Gaither, 396 N.J.

22
MAYOR, & C., OF ALPINE BOROUGH v. Brewstergreen
nj · 1951 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025To establish a claim of ineffective assistance of counsel, a defendant must satisfy the two-prong Strickland test: (1) "counsel made errors so serious that counsel was not functioning as the 'counsel' guaranteed the defendant by the Sixth Amendment"; and (2) "the deficient performance prejudiced the defense." Strickland v. Washington, 466 U.S. 668, 687 (1984); see also State v. Fritz, 105 A-2799-23 7 N.J. 42, 58 (1987) (adopting the Strickland two-prong test in New Jersey).

11
McMann v. Richardsongreen
scotus · 1970 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025With respect to prong one, a defendant must establish that "counsel's representation fell below an objective standard of reasonableness." An attorney's performance will not be deemed deficient if counsel acted "'within the range of competence demanded of attorneys in criminal cases'" as the Constitution requires only "reasonably effective assistance." Id. at 687 (quoting McMann v. Richardson, 397 U.S. 759, 771 (1970)).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
State v. Davis green
nj · 1989
2 sentences

1999Subsequently, in State v. Davis, we determined that the Strickland/Fritz standard would “adequately fulfill the constitutional guarantee” in capital cases. 116 N.J. 341, 357 , 561 A.2d 1082 (1989).

1999Subsequently, in State v. Davis, we determined that the Strickland/Fritz standard would “adequately fulfill the constitutional guarantee” in capital cases. 116 N.J. 341, 357 , 561 A.2d 1082 (1989).

11999–1999

Statutes the citing opinions construe

NJ § N.J. Stat. § 2C:43-7.2 (48) NJ § N.J. Stat. § 2C:39-4 (32) NJ § N.J. Stat. § 2C:39-5 (31) NJ § N.J. Stat. § 2C:11-3 (28) NJ § N.J. Stat. § 2C:15-1 (22) NJ § N.J. Stat. § 2C:44-1 (16) NJ § N.J. Stat. § 2C:11-4 (15) NJ § N.J. Stat. § 2C:39-7 (13) NJ § N.J. Stat. § 2C:12-1 (10) NJ § N.J. Stat. § 2C:5-1 (9) NJ § N.J. Stat. § 2C:5-2 (9) NJ § N.J. Stat. § 2C:35-5 (8)

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

NJ 79 (1999–2026) TX 21 (1992–2025) MO 12 (1989–2017) ID 11 (2004–2025) FL 10 (2005–2024) MD 4 (1997–2020) IL 3 (1996–2024) KS 2 (1992–2003) NM 2 (2017–2017)

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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