particularized prejudice inquiry (South Carolina) · Go Syfert
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particularized prejudice inquiry in South Carolina

7 South Carolina opinions name it 2 courts 2002–2025 1 in the last five years

The cases below were cited by South Carolina 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 (5)

CaseFollowedCited
Frett v. Stategreen
sc · 1988 · cited in 3 South Carolina opinions naming this issue, 2002–2006
2 sentences

2006We again recognize that this type of “consistently inept form of lawyer conduct [is not] acceptable in this state, nor will we employ a prejudice analysis, for ‘[defense] counsel’s ineffectiveness [is] so pervasive as to render a particularized prejudice inquiry unnecessary.’ ” Nance, 358 S.C. at 490 , 596 S.E.2d at 67 . (citing Frett v. State, 298 S.C. 54, 56 , 378 S.E.2d 249, 251 (1988)).

2006We again recognize that this type of “consistently inept form of lawyer conduct [is not] acceptable in this state, nor will we employ a prejudice analysis, for ‘[defense] counsel’s ineffectiveness [is] so pervasive as to render a particularized prejudice inquiry unnecessary.’ ” Nance, 358 S.C. at 490 , 596 S.E.2d at 67 . (citing Frett v. State, 298 S.C. 54, 56 , 378 S.E.2d 249, 251 (1988)).

23
Green v. Stategreen
sc · 2002 · cited in 2 South Carolina opinions naming this issue, 2006–2008
2 sentences

2008Although an applicant “must ordinarily show actual prejudice, he may be relieved of that burden if counsel’s ineffectiveness is so pervasive as to render a particularized prejudice inquiry unnecessary.” Green v. State, 351 S.C. 184, 196 , 569 S.E.2d 318, 324 (2002).

2008Although an applicant “must ordinarily show actual prejudice, he may be relieved of that burden if counsel’s ineffectiveness is so pervasive as to render a particularized prejudice inquiry unnecessary.” Green v. State, 351 S.C. 184, 196 , 569 S.E.2d 318, 324 (2002).

22
Weaver v. Massachusettsgreen
scotus · 2017 · cited in 1 South Carolina opinions naming this issue, 2025–2025
1 sentence

2025Importantly, this holding is not in conflict with Weaver, which reinforced existing jurisprudence holding that "in the case of a structural error where there is an objection at trial and the issue is raised on direct appeal, the defendant generally is entitled to 'automatic reversal' regardless of the error's actual 'effect on the outcome.'" 582 U.S. at 299 (emphasis added).

11
In re Allmongreen
sc · 2013 · cited in 1 South Carolina opinions naming this issue, 2025–2025
2 sentences

2025Initially, we acknowledge Rivera's holding that "a trial court's improper refusal to permit a defendant to testify in his own defense . . . is not amenable to harmless-error analysis" and "requires reversal without a particularized prejudice inquiry." 402 S.C. at 247 , 741 S.E.2d at 706 (emphasis added).

2025However, our supreme court determined such an "error is not amenable to harmless-error analysis and requires reversal without a particularized prejudice inquiry." Id.

11
United States v. Gonzalez-Lopezgreen
scotus · 2006 · cited in 1 South Carolina opinions naming this issue, 2013–2013
2 sentences

2013See Gonzalez-Lopez, 548 U.S. at 150 , 126 S.Ct. 2557 (“We have little trouble concluding that erroneous deprivation of the right to counsel of choice, “with consequences that are necessarily unquantifiable and indeterminate, unquestionably qualifies as structural error.’ ...

2013See Gonzalez-Lopez, 548 U.S. at 150 , 126 S.Ct. 2557 (“We have little trouble concluding that erroneous deprivation of the right to counsel of choice, “with consequences that are necessarily unquantifiable and indeterminate, unquestionably qualifies as structural error.’ ...

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
State v. Rivera green
sc · 2013
1 sentence

2025Initially, we acknowledge Rivera's holding that "a trial court's improper refusal to permit a defendant to testify in his own defense . . . is not amenable to harmless-error analysis" and "requires reversal without a particularized prejudice inquiry." 402 S.C. at 247 , 741 S.E.2d at 706 (emphasis added).

12025–2025
Nance v. Frederick neutral
sc · 2004
2 sentences

2006We again recognize that this type of “consistently inept form of lawyer conduct [is not] acceptable in this state, nor will we employ a prejudice analysis, for ‘[defense] counsel’s ineffectiveness [is] so pervasive as to render a particularized prejudice inquiry unnecessary.’ ” Nance, 358 S.C. at 490 , 596 S.E.2d at 67 . (citing Frett v. State, 298 S.C. 54, 56 , 378 S.E.2d 249, 251 (1988)).

2006We again recognize that this type of “consistently inept form of lawyer conduct [is not] acceptable in this state, nor will we employ a prejudice analysis, for ‘[defense] counsel’s ineffectiveness [is] so pervasive as to render a particularized prejudice inquiry unnecessary.’ ” Nance, 358 S.C. at 490 , 596 S.E.2d at 67 . (citing Frett v. State, 298 S.C. 54, 56 , 378 S.E.2d 249, 251 (1988)).

12006–2006

Where else courts name it

SC 7 (2002–2025) NM 3 (2023–2024)

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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