defendant makes a pretrial challenge in District of Columbia

8 District of Columbia opinions name it 1 courts 1978–2017 0 in the last five years

The cases below were cited by District of Columbia 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)

Case	Followed	Cited
Monroe v. United Statesgreen dc · 1978 · cited in 5 District of Columbia opinions naming this issue, 1980–2017 2 sentences 2017“When a defendant makes a pretrial challenge to the effectiveness of counsel ..., the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations.” Monroe v. United States, 389 A.2d 811, 820 (D.C. 1978). 1992Under Monroe , “when a defendant makes a pretrial challenge to the effectiveness of counsel ... the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations.” 389 A.2d at 820 .	2	5
William Brown, Jr. v. United Statesgreen cadc · 1959 · cited in 2 District of Columbia opinions naming this issue, 1978–1980 2 sentences 1980Faced with such a situation in another case, we recently stated: When a defendant makes a pretrial challenge to the effectiveness of counsel— whether court-appointed or retained— and requests the appointment of new counsel on the ground that counsel, due to lack of investigation, preparation, or other substantial reason, is not rendering reasonably effective assistance, the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations. [Monroe v. United States, D.C.App., 389 A.2d 811, 820 (1978) (citations omitted).] See 1980Faced with such a situation in another case, we recently stated: When a defendant makes a pretrial challenge to the effectiveness of counsel— whether court-appointed or retained— and requests the appointment of new counsel on the ground that counsel, due to lack of investigation, preparation, or other substantial reason, is not rendering reasonably effective assistance, the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations. [Monroe v. United States, D.C.App., 389 A.2d 811, 820 (1978) (citations omitted).] See	2	2
Bass v. United Statesgreen dc · 1990 · cited in 2 District of Columbia opinions naming this issue, 1992–2006 2 sentences 2006See, e.g., Mills v. United States, 796 A.2d 26, 28 (D.C.2002) (“In Monroe we held that: ‘When a defendant makes a pretrial challenge to the effectiveness of counsel ... ’ ”); Garrett v. United States, 642 A.2d 1312 , 1314 n. 1 (D.C.1994) (“Under ... the Monroe/Farrell rule, when an accused raised pretrial claims of ineffective assistance ... ”); Bass v. United States, 580 A.2d 669, 670 (D.C. 1990) (quoting Monroe). 1992The requirement of such an inquiry “ ‘has been reaffirmed by this court on numerous occasions.’ ” Nelson, supra, 601 A.2d at 592 (quoting Bass, supra, 580 A.2d at 671 ).	1	2
Portillo v. United Statesgreen dc · 2013 · cited in 1 District of Columbia opinions naming this issue, 2017–2017 1 sentence 2017That inquiry “is necessarily dependent upon the circumstances presented in each individual case, and thus must be committed to the sound discretion of the trial court.” Portillo v. United States, 62 A.3d 1243, 1252 (D.C. 2013) (quoting Monroe, 389 A.2d at 821 ).	1	1
Mills v. United Statesgreen dc · 2002 · cited in 1 District of Columbia opinions naming this issue, 2006–2006 1 sentence 2006See, e.g., Mills v. United States, 796 A.2d 26, 28 (D.C.2002) (“In Monroe we held that: ‘When a defendant makes a pretrial challenge to the effectiveness of counsel ... ’ ”); Garrett v. United States, 642 A.2d 1312 , 1314 n. 1 (D.C.1994) (“Under ... the Monroe/Farrell rule, when an accused raised pretrial claims of ineffective assistance ... ”); Bass v. United States, 580 A.2d 669, 670 (D.C. 1990) (quoting Monroe).	1	1
Farrell v. United Statesgreen dc · 1978 · cited in 1 District of Columbia opinions naming this issue, 1981–1981 2 sentences 1981Accord, Farrell v. United States, D.C.App., 391 A.2d 755 (1978). 1981Accord, Farrell v. United States, D.C.App., 391 A.2d 755 (1978).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Also cited on this issue (14)

Case	Cited	Years
Stone v. United States green scotus · 1978 2 sentences 1981To be sure, “[w]hen a defendant makes a pretrial challenge to the effectiveness of counsel ... and requests the appointment of new counsel ... the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations.” Monroe v. United States, D.C.App., 389 A.2d 811, 820 , cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 5 L.Ed.2d 683 (1978). 1981To be sure, "[w]hen a defendant makes a pretrial challenge to the effectiveness of counsel ... and requests the appointment of new counsel... the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant's allegations." Monroe v. United States, D.C.App., 389 A.2d 811, 820 , cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 5 L.Ed.2d 683 (1978).	2	1980–1981
Monroe v. United States green scotus · 1978 2 sentences 1981To be sure, “[w]hen a defendant makes a pretrial challenge to the effectiveness of counsel ... and requests the appointment of new counsel ... the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations.” Monroe v. United States, D.C.App., 389 A.2d 811, 820 , cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 5 L.Ed.2d 683 (1978). 1981To be sure, "[w]hen a defendant makes a pretrial challenge to the effectiveness of counsel ... and requests the appointment of new counsel... the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant's allegations." Monroe v. United States, D.C.App., 389 A.2d 811, 820 , cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 5 L.Ed.2d 683 (1978).	2	1980–1981
Ortega v. Bibb green scotus · 1959 2 sentences 1980Faced with such a situation in another case, we recently stated: When a defendant makes a pretrial challenge to the effectiveness of counsel— whether court-appointed or retained— and requests the appointment of new counsel on the ground that counsel, due to lack of investigation, preparation, or other substantial reason, is not rendering reasonably effective assistance, the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations. [Monroe v. United States, D.C.App., 389 A.2d 811, 820 (1978) (citations omitted).] See 1980App., 389 A.2d 811, 820 (1978) (citations omitted).] *864 See also Thornton v. United States, supra at 434-35; Brown v. United States, 105 U.S.App.D.C. 77, 83 , 264 F.2d 363, 369 (en banc) (Burger, J., concurring), cert. denied, 360 U.S. 911 , 79 S.Ct. 1299 , 3 L.Ed.2d 1262 (1959).	2	1978–1980
Walker v. Washington green scotus · 1959 2 sentences 1980Faced with such a situation in another case, we recently stated: When a defendant makes a pretrial challenge to the effectiveness of counsel— whether court-appointed or retained— and requests the appointment of new counsel on the ground that counsel, due to lack of investigation, preparation, or other substantial reason, is not rendering reasonably effective assistance, the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations. [Monroe v. United States, D.C.App., 389 A.2d 811, 820 (1978) (citations omitted).] See 1980App., 389 A.2d 811, 820 (1978) (citations omitted).] *864 See also Thornton v. United States, supra at 434-35; Brown v. United States, 105 U.S.App.D.C. 77, 83 , 264 F.2d 363, 369 (en banc) (Burger, J., concurring), cert. denied, 360 U.S. 911 , 79 S.Ct. 1299 , 3 L.Ed.2d 1262 (1959).	2	1978–1980
Hightower v. Bibb green scotus · 1959 2 sentences 1980Faced with such a situation in another case, we recently stated: When a defendant makes a pretrial challenge to the effectiveness of counsel— whether court-appointed or retained— and requests the appointment of new counsel on the ground that counsel, due to lack of investigation, preparation, or other substantial reason, is not rendering reasonably effective assistance, the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations. [Monroe v. United States, D.C.App., 389 A.2d 811, 820 (1978) (citations omitted).] See 1980App., 389 A.2d 811, 820 (1978) (citations omitted).] *864 See also Thornton v. United States, supra at 434-35; Brown v. United States, 105 U.S.App.D.C. 77, 83 , 264 F.2d 363, 369 (en banc) (Burger, J., concurring), cert. denied, 360 U.S. 911 , 79 S.Ct. 1299 , 3 L.Ed.2d 1262 (1959).	2	1978–1980
Garrett v. United States green dc · 1994 1 sentence 2006See, e.g., Mills v. United States, 796 A.2d 26, 28 (D.C.2002) (“In Monroe we held that: ‘When a defendant makes a pretrial challenge to the effectiveness of counsel ... ’ ”); Garrett v. United States, 642 A.2d 1312 , 1314 n. 1 (D.C.1994) (“Under ... the Monroe/Farrell rule, when an accused raised pretrial claims of ineffective assistance ... ”); Bass v. United States, 580 A.2d 669, 670 (D.C. 1990) (quoting Monroe).	1	2006–2006
Moore v. United States green dc · 1996 1 sentence 2002In Moore v. United States, 675 A.2d 71 (D.C.1996), we summarized the Monroe-Farrell inquiry requirements: In Monroe we held that: “When a defendant makes a pretrial challenge to the effectiveness of counsel ... on the ground that counsel, due to lack of investigation, preparation or other substantial reason, is not rendering reasonably effective assistance, the trial court has a constitutional duty to conduct an inquiry sufficient to determine the truth and scope of the defendant’s allegations.” 389 A.2d at 820 [ (citations omitted) ].	1	2002–2002
Nelson v. United States green dc · 1991 2 sentences 1992The requirement of such an inquiry “ ‘has been reaffirmed by this court on numerous occasions.’ ” Nelson, supra, 601 A.2d at 592 (quoting Bass, supra, 580 A.2d at 671 ). 1992The requirement of such an inquiry “ ‘has been reaffirmed by this court on numerous occasions.’ ” Nelson, supra, 601 A.2d at 592 (quoting Bass, supra, 580 A.2d at 671 ).	1	1992–1992
Thornton v. United States green dc · 1976 2 sentences 1980When this case was originally argued before a division, Judge Harris and I — Judge Mack dissenting — voted to affirm the conviction, pointing out that since it is the duty of a trial judge when a defendant makes a pretrial challenge to the effectiveness of counsel “to conduct an inquiry to determine the truth and scope of defendant’s allegations,” Monroe v. United States, D.C.App., 389 A.2d 811 , 820 cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 58 L.Ed.2d 683 (1978); Thornton v. United States, D.C.App., 357 A.2d 429 , cert. denied, 429 U.S. 1024 , 97 S.Ct. 644 , 50 L.Ed.2d 626 (1976), defense 1980When this case was originally argued before a division, Judge Harris and I — Judge Mack dissenting — voted to affirm the conviction, pointing out that since it is the duty of a trial judge when a defendant makes a pretrial challenge to the effectiveness of counsel "to conduct an inquiry to determine the truth and scope of defendant's allegations," Monroe v. United States, D.C.App., 389 A.2d 811 , 820 cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 58 L.Ed.2d 683 (1978); Thornton v. United States, D.C.App., 357 A.2d 429 , cert. denied, 429 U.S. 1024 , 97 S.Ct. 644 , 50 L.Ed.2d 626 (1976), defense	1	1980–1980
Thornton v. United States green scotus · 1976 2 sentences 1980When this case was originally argued before a division, Judge Harris and I — Judge Mack dissenting — voted to affirm the conviction, pointing out that since it is the duty of a trial judge when a defendant makes a pretrial challenge to the effectiveness of counsel “to conduct an inquiry to determine the truth and scope of defendant’s allegations,” Monroe v. United States, D.C.App., 389 A.2d 811 , 820 cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 58 L.Ed.2d 683 (1978); Thornton v. United States, D.C.App., 357 A.2d 429 , cert. denied, 429 U.S. 1024 , 97 S.Ct. 644 , 50 L.Ed.2d 626 (1976), defense 1980When this case was originally argued before a division, Judge Harris and I — Judge Mack dissenting — voted to affirm the conviction, pointing out that since it is the duty of a trial judge when a defendant makes a pretrial challenge to the effectiveness of counsel “to conduct an inquiry to determine the truth and scope of defendant’s allegations,” Monroe v. United States, D.C.App., 389 A.2d 811 , 820 cert. denied, 439 U.S. 1006 , 99 S.Ct. 621 , 58 L.Ed.2d 683 (1978); Thornton v. United States, D.C.App., 357 A.2d 429 , cert. denied, 429 U.S. 1024 , 97 S.Ct. 644 , 50 L.Ed.2d 626 (1976), defense	1	1980–1980
Ben Lee Brown v. Walter E. Craven green ca9 · 1970 1 sentence 1978United States v. Young, 482 F.2d 993 (5th Cir. 1973); Sawicki v. Johnson, 475 F.2d 183 (6th Cir. 1973); United States v. Morrissey, supra; Brown v. Craven, 424 F.2d 1166 (9th Cir. 1970); Brown v. United States, 105 U.S.App.D.C. 77 , 264 F.2d 363, 367-69 (en banc) (Burger, J., concurring), cert. denied, 360 U.S. 911 , 79 S.Ct. 1299 , 3 L.Ed.2d 1262 (1959).	1	1978–1978
United States v. Reginald A. Morrissey green ca2 · 1972 1 sentence 1978United States v. Young, 482 F.2d 993 (5th Cir. 1973); Sawicki v. Johnson, 475 F.2d 183 (6th Cir. 1973); United States v. Morrissey, supra; Brown v. Craven, 424 F.2d 1166 (9th Cir. 1970); Brown v. United States, 105 U.S.App.D.C. 77 , 264 F.2d 363, 367-69 (en banc) (Burger, J., concurring), cert. denied, 360 U.S. 911 , 79 S.Ct. 1299 , 3 L.Ed.2d 1262 (1959).	1	1978–1978
Chester Sawicki v. Perry Johnson, Warden green ca6 · 1973 1 sentence 1978United States v. Young, 482 F.2d 993 (5th Cir. 1973); Sawicki v. Johnson, 475 F.2d 183 (6th Cir. 1973); United States v. Morrissey, supra; Brown v. Craven, 424 F.2d 1166 (9th Cir. 1970); Brown v. United States, 105 U.S.App.D.C. 77 , 264 F.2d 363, 367-69 (en banc) (Burger, J., concurring), cert. denied, 360 U.S. 911 , 79 S.Ct. 1299 , 3 L.Ed.2d 1262 (1959).	1	1978–1978
United States v. James Earl Young, Sr. green ca5 · 1973 1 sentence 1978United States v. Young, 482 F.2d 993 (5th Cir. 1973); Sawicki v. Johnson, 475 F.2d 183 (6th Cir. 1973); United States v. Morrissey, supra; Brown v. Craven, 424 F.2d 1166 (9th Cir. 1970); Brown v. United States, 105 U.S.App.D.C. 77 , 264 F.2d 363, 367-69 (en banc) (Burger, J., concurring), cert. denied, 360 U.S. 911 , 79 S.Ct. 1299 , 3 L.Ed.2d 1262 (1959).	1	1978–1978

Statutes the citing opinions construe

DC § D.C. Code § 23-110 (4) DC § D.C. Code § 22-1801 (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

DC 8 (1978–2017) TX 7 (2006–2008)

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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