duress defense (Oklahoma) · Go Syfert
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duress defense in Oklahoma

8 Oklahoma opinions name it 2 courts 1931–2003 0 in the last five years

The cases below were cited by Oklahoma 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 (4)

CaseFollowedCited
Tully v. Stategreen
oklacrimapp · 1986 · cited in 2 Oklahoma opinions naming this issue, 2002–2003
2 sentences

2002Lumpkin dissenting)("the defense of duress is not applicable to first degree malice aforethought murder."); Tully v. State, 1986 OK CR 185 , 730 P.2d 1206, 1210 (discussing how the common law's, and hence Oklahoma's, rationale for denial of the duress defense to intentional killing "is premised on the theory that one should risk or sacrifice one's own life rather than take the life of an innocent person.") [8] I continue to disagree, however, for the reasons stated in my dissent in Spunaugle . [9] See 21 O.S.1991, § 152(7); 21 O.S.1991, § 155. [10] See Shrum v. State, 1999 OK CR 41 , 991 P.2d

2002Lumpkin dissenting)("the defense of duress is not applicable to first degree malice aforethought murder."); Tully v. State, 1986 OK CR 185 , 730 P.2d 1206, 1210 (discussing how the common law's, and hence Oklahoma's, rationale for denial of the duress defense to intentional killing "is premised on the theory that one should risk or sacrifice one's own life rather than take the life of an innocent person.") [8] I continue to disagree, however, for the reasons stated in my dissent in Spunaugle . [9] See 21 O.S.1991, § 152(7); 21 O.S.1991, § 155. [10] See Shrum v. State, 1999 OK CR 41 , 991 P.2d

12
Spunaugle v. Stategreen
oklacrimapp · 1997 · cited in 1 Oklahoma opinions naming this issue, 1999–1999
2 sentences

1999Therefore, I find the issue of denial of notice under Burks 1 has been waived. ¶ 3 Based on my analysis of the duress defense in Spunaugle v. State, 946 P.2d 246, 253-55 (Okl.Cr.1997) (Lumpkin, J., dissenting) I find Marvin Matheson could have been indicted for the crimes committed and therefore was an accomplice.

1999Therefore, I find the issue of denial of notice under Burks [1] has been waived. ¶ 3 Based on my analysis of the duress defense in Spunaugle v. State, 946 P.2d 246, 253-55 (Okl.Cr.1997) (Lumpkin, J., dissenting) I find Marvin Matheson could have been indicted for the crimes committed and therefore was an accomplice.

11
Grider v. Stategreen
oklacrimapp · 1987 · cited in 1 Oklahoma opinions naming this issue, 1988–1988
2 sentences

1988In the most recent case cited by the majority, this Court expressly held that “although a duress instruction might be appropriate in a proper fact situation, the facts of the instant case did not merit one.” Grider v. State, 737 P.2d 1227, 1228 (Okla.Crim.App.1987).

1988In the most recent case cited by the majority, this Court expressly held that "although a duress instruction might be appropriate in a proper fact situation, the facts of the instant case did not merit one." Grider v. State, 737 P.2d 1227, 1228 (Okla.

11
Davis v. Stategreen
oklacrimapp · 1985 · cited in 1 Oklahoma opinions naming this issue, 1986–1986
1 sentence

1986Accordingly, the duress defense was simply not available, and any language in the opinion regarding duress as it relates to the offense of murder was mere dicta. [4] See 21 O.S. 1981 , § 2. [1] Davis v. State, 709 P.2d 207, 210 (Okl.Cr. 1985).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Simmons v. South Carolina green
scotus · 1994
2 sentences

2002Lumpkin dissenting)("the defense of duress is not applicable to first degree malice aforethought murder."); Tully v. State, 1986 OK CR 185 , 730 P.2d 1206, 1210 (discussing how the common law's, and hence Oklahoma's, rationale for denial of the duress defense to intentional killing "is premised on the theory that one should risk or sacrifice one's own life rather than take the life of an innocent person.") [8] I continue to disagree, however, for the reasons stated in my dissent in Spunaugle . [9] See 21 O.S.1991, § 152(7); 21 O.S.1991, § 155. [10] See Shrum v. State, 1999 OK CR 41 , 991 P.2d

2002Lumpkin dissenting)("the defense of duress is not applicable to first degree malice aforethought murder."); Tully v. State, 1986 OK CR 185 , 730 P.2d 1206, 1210 (discussing how the common law's, and hence Oklahoma's, rationale for denial of the duress defense to intentional killing "is premised on the theory that one should risk or sacrifice one's own life rather than take the life of an innocent person.") [8] I continue to disagree, however, for the reasons stated in my dissent in Spunaugle . [9] See 21 O.S.1991, § 152(7); 21 O.S.1991, § 155. [10] See Shrum v. State, 1999 OK CR 41 , 991 P.2d

12002–2002
Shrum v. State green
oklacrimapp · 1999
2 sentences

2002Lumpkin dissenting)("the defense of duress is not applicable to first degree malice aforethought murder."); Tully v. State, 1986 OK CR 185 , 730 P.2d 1206, 1210 (discussing how the common law's, and hence Oklahoma's, rationale for denial of the duress defense to intentional killing "is premised on the theory that one should risk or sacrifice one's own life rather than take the life of an innocent person.") [8] I continue to disagree, however, for the reasons stated in my dissent in Spunaugle . [9] See 21 O.S.1991, § 152(7); 21 O.S.1991, § 155. [10] See Shrum v. State, 1999 OK CR 41 , 991 P.2d

2002Lumpkin dissenting)("the defense of duress is not applicable to first degree malice aforethought murder."); Tully v. State, 1986 OK CR 185 , 730 P.2d 1206, 1210 (discussing how the common law's, and hence Oklahoma's, rationale for denial of the duress defense to intentional killing "is premised on the theory that one should risk or sacrifice one's own life rather than take the life of an innocent person.") [8] I continue to disagree, however, for the reasons stated in my dissent in Spunaugle . [9] See 21 O.S.1991, § 152(7); 21 O.S.1991, § 155. [10] See Shrum v. State, 1999 OK CR 41 , 991 P.2d

12002–2002
Strickland v. Washington green
scotus · 1984
2 sentences

1999However, sufficient evidence was presented to corroborate his testimony and there is no plain error. ¶ 4 Further, it should be noted the criteria set out in Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984), for evaluating effectiveness of counsel has been further explained in Lockhart v. Fretwell, 506 U.S. 364 , 113 S.Ct. 838 , 122 L.Ed.2d 180 (1993).

1999However, sufficient evidence was presented to corroborate his testimony and there is no plain error. ¶ 4 Further, it should be noted the criteria set out in Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984), for evaluating effectiveness of counsel has been further explained in Lockhart v. Fretwell, 506 U.S. 364 , 113 S.Ct. 838 , 122 L.Ed.2d 180 (1993).

11999–1999
Lockhart v. Fretwell green
scotus · 1993
2 sentences

1999However, sufficient evidence was presented to corroborate his testimony and there is no plain error. ¶ 4 Further, it should be noted the criteria set out in Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984), for evaluating effectiveness of counsel has been further explained in Lockhart v. Fretwell, 506 U.S. 364 , 113 S.Ct. 838 , 122 L.Ed.2d 180 (1993).

1999However, sufficient evidence was presented to corroborate his testimony and there is no plain error. ¶ 4 Further, it should be noted the criteria set out in Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984), for evaluating effectiveness of counsel has been further explained in Lockhart v. Fretwell, 506 U.S. 364 , 113 S.Ct. 838 , 122 L.Ed.2d 180 (1993).

11999–1999
Traxler v. State green
oklacrimapp · 1952
2 sentences

1986It is true, as Judge Bussey states, that our statute on duress “does not state against whom the threat of harm must exist”, and that “[i]n such an instance, the common law should be consulted in to construe that statute. 22 O.S. 1981 , § 9; Traxler v. State, 96 Okl.Cr. 231 , 251 P.2d 815 (1953).” Supra at 98.

1986It is true, as Judge Bussey states, that our statute on duress “does not state against whom the threat of harm must exist”, and that “[i]n such an instance, the common law should be consulted in to construe that statute. 22 O.S. 1981 , § 9; Traxler v. State, 96 Okl.Cr. 231 , 251 P.2d 815 (1953).” Supra at 98.

11986–1986
Stratton v. State neutral
oklacrimapp · 1982
1 sentence

1985Stratton v. State, 643 P.2d 645 (Okl.Cr.1982).

11985–1985
Callendar Savings Bank v. Loos green
iowa · 1909
1 sentence

1931Bank v. Loos (Iowa), 120 N. W. 317 .

11931–1931

Statutes the citing opinions construe

OK § Okla. Stat. tit. 21, § 156 (4) OK § Okla. Stat. tit. 21, § 152 (3) OK § Okla. Stat. tit. 21, § 155 (3) OK § Okla. Stat. tit. 21, § 701.7 (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 62 (1976–2025) NM 41 (1982–2026) MI 40 (1975–2025) PA 31 (1974–2025) TX 28 (1991–2026) WA 25 (1988–2025) NY 25 (1983–2025) OH 24 (1977–2026) AZ 15 (1984–2025) NJ 14 (1988–2025) FL 14 (1981–2024) MD 12 (1970–2021) CO 12 (1998–2024) MS 12 (1994–2017) ME 9 (1993–2021) NC 9 (1983–2022) IL 8 (1989–2026) OK 8 (1931–2003) MO 7 (1885–2019) CT 7 (1987–2015) GA 5 (1981–2019) WY 4 (1992–2015) NV 4 (2019–2020) DC 4 (1996–2009) MA 4 (2000–2023) TN 4 (2005–2019) SD 4 (1985–2025) VA 4 (2005–2025) UT 3 (1986–2003) DE 3 (1998–2024) RI 3 (2000–2008) OR 3 (1978–2025) AL 3 (1991–2005) IN 3 (1988–2018) KS 2 (1991–2011) AK 2 (2001–2021) WV 2 (2002–2014) MN 2 (2002–2008) HI 2 (2000–2007) NE 2 (1987–2020)

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.

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