Strickland test in Connecticut

300 Connecticut opinions name it 3 courts 1989–2026 43 in the last five years

The cases below were cited by Connecticut 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 (31)

Case	Followed	Cited
Hill v. Lockhartgreen scotus · 1985 · cited in 34 Connecticut opinions naming this issue, 1995–2025 2 sentences 2025In the context of a guilty plea, the Strickland test requires the petitioner to prove that counsel’s conduct falls outside of the range of reasonable professional assistance and to show that, ‘‘but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.’’ Hill v. Lockhart, 474 U.S. 52, 59 , 106 S. Ct. 366 , 88 L. 2025In the context of a guilty plea, the Strickland test requires the petitioner to prove that counsel’s conduct falls outside of the range of reasonable professional assistance and to show that, ‘‘but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.’’ Hill v. Lockhart, 474 U.S. 52, 59 , 106 S. Ct. 366 , 88 L.	4	34
Fair v. Commissioner of Correctiongreen connappct · 2021 · cited in 3 Connecticut opinions naming this issue, 2021–2026	3	3
Johnson v. Commissioner of Correctiongreen conn · 1991 · cited in 46 Connecticut opinions naming this issue, 1993–2018 2 sentences 2018See Johnson v. Commissioner of Correction , 218 Conn. 403 , 419, 589 A.2d 1214 (1991) (reviewing court can find against petitioner on either prong of Strickland ); see also Martin v. Commissioner of Correction , 141 Conn. App. 99 , 102-103, 60 A.3d 997 ("[i]f ... the petitioner fail[s] to satisfy the performance prong of the Strickland standard, that determination is dispositive of the petitioner's habeas claims, and it is unnecessary for the court to reach the prejudice prong"), cert. denied, 308 Conn. 923 , 94 A.3d 638 (2013). 2018See Johnson v. Commissioner of Correction , 218 Conn. 403 , 419, 589 A.2d 1214 (1991) (reviewing court can find against petitioner on either prong of Strickland ); see also Martin v. Commissioner of Correction , 141 Conn. App. 99 , 102-103, 60 A.3d 997 ("[i]f ... the petitioner fail[s] to satisfy the performance prong of the Strickland standard, that determination is dispositive of the petitioner's habeas claims, and it is unnecessary for the court to reach the prejudice prong"), cert. denied, 308 Conn. 923 , 94 A.3d 638 (2013).	2	46
Washington v. Commissioner of Correctiongreen conn · 2008 · cited in 3 Connecticut opinions naming this issue, 2010–2020	2	3
Elsey v. Commissioner of Correctiongreen connappct · 2011 · cited in 2 Connecticut opinions naming this issue, 2017–2017	2	2
Marciano v. Kranergreen conn · 2011 · cited in 2 Connecticut opinions naming this issue, 2017–2017	2	2
Levine v. Mansongreen conn · 1985 · cited in 27 Connecticut opinions naming this issue, 1993–2021 2 sentences 1995In order to satisfy the prejudice prong of the Strickland test, the petitioner must prove, by a preponderance of the evidence, that there exists a reasonable probability that, but for counsel's unprofessional errors, the result of the proceedings would have been different, Levine v. Manson, 195 Conn. 636 (1985), p. 640. 1995In order to satisfy the prejudice prong of the Strickland test, the petitioner must prove, by a preponderance of the evidence, that there exists a reasonable probability that, but for counsel's unprofessional errors, the result of the proceedings would have been different, Levine v. Manson, 195 Conn. 636 (1985), p. 640.	1	27
Strickland v. Washingtongreen scotus · 1984 · cited in 18 Connecticut opinions naming this issue, 1990–2021 2 sentences 2021INEFFECTIVE ASSISTANCE OF HABEAS COUNSEL Our Supreme Court has adopted the two-pronged Strickland test; Strickland v. Washington, 466 U.S. 668, 687 , 104 S. Ct. 2052 , 80 L. 2021INEFFECTIVE ASSISTANCE OF HABEAS COUNSEL Our Supreme Court has adopted the two-pronged Strickland test; Strickland v. Washington, 466 U.S. 668, 687 , 104 S. Ct. 2052 , 80 L.	1	18
Lozada v. Warden, State Prisongreen conn · 1992 · cited in 11 Connecticut opinions naming this issue, 2009–2024 2 sentences 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he	1	11
Lewis v. Commissioner of Correctiongreen connappct · 2016 · cited in 6 Connecticut opinions naming this issue, 2016–2017 2 sentences 2017"It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier." Lewis v. Commissioner of Correction , 165 Conn.App. 411 , 451, 139 A.3d 759 , cert. denied, 322 Conn. 901 , 138 A.3d 931 (2016), citing Strickland v. Washington , supra, 466 U.S. at 697 , 104 S.Ct. 2052 ("a court need not determine whether counsel's performance was deficient before examining the prejudice suffered by the [petitioner]"). 2017"It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier." Lewis v. Commissioner of Correction , 165 Conn.App. 411 , 451, 139 A.3d 759 , cert. denied, 322 Conn. 901 , 138 A.3d 931 (2016), citing Strickland v. Washington , supra, 466 U.S. at 697 , 104 S.Ct. 2052 ("a court need not determine whether counsel's performance was deficient before examining the prejudice suffered by the [petitioner]").	1	6
Copas v. Commissioner of Correctiongreen conn · 1995 · cited in 6 Connecticut opinions naming this issue, 1995–2010 2 sentences 2010Ed. 2d 708 (2003); State v. Wilcox, 254 Conn. 441, 454 , 758 A.2d 824 (2000) (Brady claim); Copas v. Commissioner of Correction, 234 Conn. 139, 155 , 662 A.2d 718 (1995) (Strickland claim); Fair v. Warden, 211 Conn. 398, 408 , 559 A.2d 1094 (Strickland claim), cert. denied, 493 U.S. 981 , 110 S. Ct. 512 , 107 L. 2010Ed. 2d 708 (2003); State v. Wilcox, 254 Conn. 441, 454 , 758 A.2d 824 (2000) (Brady claim); Copas v. Commissioner of Correction, 234 Conn. 139, 155 , 662 A.2d 718 (1995) (Strickland claim); Fair v. Warden, 211 Conn. 398, 408 , 559 A.2d 1094 (Strickland claim), cert. denied, 493 U.S. 981 , 110 S. Ct. 512 , 107 L.	1	6
Denby v. Commissioner of Correctiongreen connappct · 2001 · cited in 6 Connecticut opinions naming this issue, 2001–2009 2 sentences 2003Because both prongs of the Strickland test must be established for a habeas Petitioner to prevail, a court may dismiss a Petitioner's claim if he fails to meet either prong Denby v. Commissioner of Correction, 66 Conn. App. 809 , 813 , 786 A.2d 442 (2001), cert. denied, 259 Conn. 908 , 789 A.2d 994 (2002). 2003Because both prongs of the Strickland test must be established for a habeas Petitioner to prevail, a court may dismiss a Petitioner's claim if he fails to meet either prong Denby v. Commissioner of Correction, 66 Conn. App. 809 , 813 , 786 A.2d 442 (2001), cert. denied, 259 Conn. 908 , 789 A.2d 994 (2002).	1	6
Colon v. Commissioner of Correctiongreen connappct · 2017 · cited in 5 Connecticut opinions naming this issue, 2019–2023 2 sentences 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail	1	5
Bozelko v. Statewide Constr., Inc.green conn · 2018 · cited in 5 Connecticut opinions naming this issue, 2019–2023 2 sentences 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail	1	5
State v. Azevedogreen conn · 2018 · cited in 5 Connecticut opinions naming this issue, 2019–2023 2 sentences 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail	1	5
King v. Commissioner of Correctiongreen connappct · 2002 · cited in 5 Connecticut opinions naming this issue, 2003–2018 2 sentences 2018"Because both prongs of the Strickland test must be established for a habeas petitioner to prevail, a court may dismiss a petitioner's claim if he fails to meet either prong." King v. Commissioner of Correction , 73 Conn. App. 600 , 602-603, 808 A.2d 1166 (2002), cert. denied, 262 Conn. 931 , 815 A.2d 133 (2003). 2018"Because both prongs of the Strickland test must be established for a habeas petitioner to prevail, a court may dismiss a petitioner's claim if he fails to meet either prong." King v. Commissioner of Correction , 73 Conn. App. 600 , 602-603, 808 A.2d 1166 (2002), cert. denied, 262 Conn. 931 , 815 A.2d 133 (2003).	1	5
Lemoine v. Commissionergreen conn · 2003 · cited in 5 Connecticut opinions naming this issue, 2004–2018 2 sentences 2018"Because both prongs of the Strickland test must be established for a habeas petitioner to prevail, a court may dismiss a petitioner's claim if he fails to meet either prong." King v. Commissioner of Correction , 73 Conn. App. 600 , 602-603, 808 A.2d 1166 (2002), cert. denied, 262 Conn. 931 , 815 A.2d 133 (2003). 2018"Because both prongs of the Strickland test must be established for a habeas petitioner to prevail, a court may dismiss a petitioner's claim if he fails to meet either prong." King v. Commissioner of Correction , 73 Conn. App. 600 , 602-603, 808 A.2d 1166 (2002), cert. denied, 262 Conn. 931 , 815 A.2d 133 (2003).	1	5
State v. Martinezgreen conn · 2002 · cited in 5 Connecticut opinions naming this issue, 2002–2009 2 sentences 2003Because both prongs of the Strickland test must be established for a habeas Petitioner to prevail, a court may dismiss a Petitioner's claim if he fails to meet either prong Denby v. Commissioner of Correction, 66 Conn. App. 809 , 813 , 786 A.2d 442 (2001), cert. denied, 259 Conn. 908 , 789 A.2d 994 (2002). 2003Because both prongs of the Strickland test must be established for a habeas Petitioner to prevail, a court may dismiss a Petitioner's claim if he fails to meet either prong Denby v. Commissioner of Correction, 66 Conn. App. 809 , 813 , 786 A.2d 442 (2001), cert. denied, 259 Conn. 908 , 789 A.2d 994 (2002).	1	5
Gordon v. Glassgreen conn · 2002 · cited in 5 Connecticut opinions naming this issue, 2002–2009 2 sentences 2003Because both prongs of the Strickland test must be established for a habeas Petitioner to prevail, a court may dismiss a Petitioner's claim if he fails to meet either prong Denby v. Commissioner of Correction, 66 Conn. App. 809 , 813 , 786 A.2d 442 (2001), cert. denied, 259 Conn. 908 , 789 A.2d 994 (2002). 2003Because both prongs of the Strickland test must be established for a habeas Petitioner to prevail, a court may dismiss a Petitioner's claim if he fails to meet either prong Denby v. Commissioner of Correction, 66 Conn. App. 809 , 813 , 786 A.2d 442 (2001), cert. denied, 259 Conn. 908 , 789 A.2d 994 (2002).	1	5
State v. Pereiragreen conn · 2003 · cited in 4 Connecticut opinions naming this issue, 2004–2018	1	4
Small v. Commissioner of Correctiongreen conn · 2008 · cited in 4 Connecticut opinions naming this issue, 2013–2017	1	4
Valeriano v. Bronsongreen conn · 1988 · cited in 3 Connecticut opinions naming this issue, 1992–2017	1	3
Fair v. Wardengreen conn · 1989 · cited in 3 Connecticut opinions naming this issue, 2000–2016	1	3
Mozell v. Commissioner of Correctiongreen conn · 2009 · cited in 3 Connecticut opinions naming this issue, 2010–2016	1	3
Davis v. Comm'r of Corr.green conn · 2019 · cited in 2 Connecticut opinions naming this issue, 2024–2026	1	2
State v. Correagreen conn · 2019 · cited in 2 Connecticut opinions naming this issue, 2024–2026	1	2
Ricardo R. v. Commissioner of Correctiongreen connappct · 2018 · cited in 2 Connecticut opinions naming this issue, 2024–2026	1	2
Bonds v. Commissioner of Correctiongreen connappct · 2024 · cited in 2 Connecticut opinions naming this issue, 2024–2025	1	2
Smith v. Commissioner of Correctiongreen connappct · 2005 · cited in 2 Connecticut opinions naming this issue, 2006–2019	1	2
Smith v. Commissioner of Correctiongreen conn · 2005 · cited in 2 Connecticut opinions naming this issue, 2006–2019	1	2
Williams v. Taylorgreen scotus · 2000 · cited in 2 Connecticut opinions naming this issue, 2010–2018	1	2

Distinguished, questioned or overruled (0)

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

Also cited on this issue (49)

Case	Cited	Years
Ostolaza v. Warden green connappct · 1992 2 sentences 2008To meet the second prong of the Strickland test, the petitioner must show that “counsel’s errors were so serious as to deprive [him] of a fair trial, a trial whose result is reliable.” Strickland v. Washington, supra, 466 U.S. 687 . “[T]he petitioner’s burden of proving that afundamental unfairness [has] been done is not met by speculation but by demonstrable realities.” Ostolaza v. Warden, 26 Conn. App. 758, 765 , 603 A.2d 768 , cert. denied. 222 Conn. 906 , 608 A.2d 692 (1992). 2008To meet the second prong of the Strickland test, the petitioner must show that “counsel’s errors were so serious as to deprive [him] of a fair trial, a trial whose result is reliable.” Strickland v. Washington, supra, 466 U.S. 687 . “[T]he petitioner’s burden of proving that afundamental unfairness [has] been done is not met by speculation but by demonstrable realities.” Ostolaza v. Warden, 26 Conn. App. 758, 765 , 603 A.2d 768 , cert. denied. 222 Conn. 906 , 608 A.2d 692 (1992).	48	1993–2013
Bunkley v. Commissioner of Correction green conn · 1992 2 sentences 2008“The seminal case of Bunkley v. Commissioner of Correction, [ 222 Conn. 444 , 610 A.2d 598 (1992)], considered the prejudice prong of the Strickland analysis in claims of ineffective assistance of appellate counsel. 2008“The seminal case of Bunkley v. Commissioner of Correction, [ 222 Conn. 444 , 610 A.2d 598 (1992)], considered the prejudice prong of the Strickland analysis in claims of ineffective assistance of appellate counsel.	29	1993–2008
State v. Robles green conn · 2017 2 sentences 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail	7	2017–2022
Flomo v. Commissioner of Correction green connappct · 2016 2 sentences 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail 2022A reasonable probability is a probability sufficient to undermine con- fidence in the outcome.’’ (Internal quotation marks omitted.) Wargo v. Commissioner of Correction, 144 Conn. App. 695 , 700–702, 73 A.3d 821 (2013), appeal dismissed, 316 Conn. 180 , 112 A.3d 777 (2015). ‘‘It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Internal quotation marks omit- ted.) Flomo v. Commissioner of Correction, 169 Conn. App. 266, 278 , 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘[T]he petitioner’s fail	7	2017–2022
Johnson v. Commissioner of Correction green conn · 2008 2 sentences 2017Johnson v. Commissioner of Correction , 285 Conn. 556 , 569-70, 941 A.2d 248 (2008) ; see also Valeriano v. Bronson , 209 Conn. 75 , 83-85, 546 A.2d 1380 (1988) ("[T]he cause and prejudice test is unnecessary when a habeas court is faced with a claim formulated within the narrow confines of ineffective assistance of appellate counsel.... [W]e conclude that it is simpler and more appropriate to move directly to the Strickland test." [Citations omitted.] ). 2017Johnson v. Commissioner of Correction , 285 Conn. 556 , 569-70, 941 A.2d 248 (2008) ; see also Valeriano v. Bronson , 209 Conn. 75 , 83-85, 546 A.2d 1380 (1988) ("[T]he cause and prejudice test is unnecessary when a habeas court is faced with a claim formulated within the narrow confines of ineffective assistance of appellate counsel.... [W]e conclude that it is simpler and more appropriate to move directly to the Strickland test." [Citations omitted.] ).	7	2008–2018
Orellana v. Commissioner of Correction neutral connappct · 2012 2 sentences 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu	6	2013–2016
Boyd v. Commissioner of Correction green connappct · 2011 2 sentences 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu	6	2013–2016
Thurlow v. HULTEN green conn · 2011 2 sentences 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu	6	2013–2016
State v. Milner green conn · 2011 2 sentences 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu 2016"To satisfy the performance prong [of the Strickland test] ... the petitioner must demonstrate that his attorney's representation was not reasonably competent or within the range of competence displayed by lawyers with ordinary training and skill in the criminal law."(Internal quotation marks omitted.) Boyd v. Commissioner of Correction, 130 Conn.App. 291 , 294-95, 21 A.3d 969 , cert. denied, 302 Conn. 926 , 28 A.3d 337 (2011). "[A] court must indulge a strong presumption that counsel's conduct falls within the wide range of 684 reasonable professional assistance; that is, the [petitioner] mu	6	2013–2016
Evans v. Warden green connappct · 1992 2 sentences 2026In habeas cases, “[w]hile . . . expert testimony is not necessarily required in every case raising a Strickland inquiry . . . presenting expert testimony may help a petitioner carry his burden in demonstrating deficient performance.” (Citation omitted.) Ricardo R. v. Com- missioner of Correction, 185 Conn. App. 787 , 802 n.8, 198 A.3d 630 (2018), cert. denied, 330 Conn. 959 , 199 A.3d 560 (2019). “[N]ot every petitioner claiming inef- fective assistance of counsel need present expert testi- mony, because as in some . . . professional malpractice cases, the acts complained of will be such that 2026In habeas cases, “[w]hile . . . expert testimony is not necessarily required in every case raising a Strickland inquiry . . . presenting expert testimony may help a petitioner carry his burden in demonstrating deficient performance.” (Citation omitted.) Ricardo R. v. Com- missioner of Correction, 185 Conn. App. 787 , 802 n.8, 198 A.3d 630 (2018), cert. denied, 330 Conn. 959 , 199 A.3d 560 (2019). “[N]ot every petitioner claiming inef- fective assistance of counsel need present expert testi- mony, because as in some . . . professional malpractice cases, the acts complained of will be such that	5	1992–2026
Padilla v. Kentucky green scotus · 2010 2 sentences 2019It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Citations omitted; footnote omit- ted; internal quotation marks omitted.) Flomo v. Com- missioner of Correction, 169 Conn. App. 266 , 277–78, 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘In its analysis, a reviewing court may look to the performance prong or the prejudice prong, and the petitioner’s failure to prove either is fatal to a habeas petition.’’ (Internal quotation marks omitted.) Colon v. Commissioner of Correction, 179 Conn. App. 2019It is axiomatic that courts may decide against a petitioner on either prong [of the Strickland test], whichever is easier.’’ (Citations omitted; footnote omit- ted; internal quotation marks omitted.) Flomo v. Com- missioner of Correction, 169 Conn. App. 266 , 277–78, 149 A.3d 185 (2016), cert. denied, 324 Conn. 906 , 152 A.3d 544 (2017). ‘‘In its analysis, a reviewing court may look to the performance prong or the prejudice prong, and the petitioner’s failure to prove either is fatal to a habeas petition.’’ (Internal quotation marks omitted.) Colon v. Commissioner of Correction, 179 Conn. App.	5	2013–2022
Harris v. Commissioner of Correction green connappct · 2008 2 sentences 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he	5	2009–2021
Harris v. Commissioner of Correction green conn · 2008 2 sentences 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he	5	2009–2021
Schwartz v. Family Dental Group, P.C. green conn · 2008 2 sentences 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he 2021The second prong is thus satisfied if the petitioner can demonstrate that there is a reasonable probability that, but for that ineffectiveness, the outcome would have been differ- ent.’’ (Internal quotation marks omitted.) Horn v. Com- missioner of Correction, 321 Conn. 767, 776 , 138 A.3d 908 (2016). ‘‘[When] applied to a claim of ineffective assistance of prior habeas counsel, the Strickland standard requires the petitioner to demonstrate that his prior habeas counsel’s performance was ineffective and that this ineffectiveness prejudiced the petitioner’s prior habeas proceeding. . . . [T]he	5	2009–2021
Aillon v. Meachum green conn · 1989 2 sentences 2015If it is easier to dispose of an ineffectiveness claim on the ground of lack of sufficient prejudice . . . that course should be followed.’’ Aillon v. Meachum, 211 Conn. 352, 362 , 559 A.2d 206 (1989), quoting Strickland v. Washington, supra, 697 ; King v. Commissioner of Correction, 73 Conn. App. 600 , 602–603, 808 A.2d 1166 (2002) (‘‘[b]ecause both prongs of the Strickland test must be established for a habeas petitioner to prevail, a court may dismiss a petitioner’s claim if he fails to meet either prong’’), cert. denied, 262 Conn. 931 , 815 A.2d 133 (2003). 2 General Statutes (Rev. to 2001 2015If it is easier to dispose of an ineffectiveness claim on the ground of lack of sufficient prejudice . . . that course should be followed.’’ Aillon v. Meachum, 211 Conn. 352, 362 , 559 A.2d 206 (1989), quoting Strickland v. Washington, supra, 697 ; King v. Commissioner of Correction, 73 Conn. App. 600 , 602–603, 808 A.2d 1166 (2002) (‘‘[b]ecause both prongs of the Strickland test must be established for a habeas petitioner to prevail, a court may dismiss a petitioner’s claim if he fails to meet either prong’’), cert. denied, 262 Conn. 931 , 815 A.2d 133 (2003). 2 General Statutes (Rev. to 2001	5	1989–2015
Do v. Comm'r of Motor Vehicles green conn · 2016	4	2017–2017
Crawford v. Commissioner of Correction green conn · 2008	4	2008–2017
Williams v. Commissioner of Correction green connappct · 2012	4	2012–2013
Soto v. Commissioner of Correction green connappct · 2022	3	2024–2025
Echeverria v. Commissioner of Correction green connappct · 2019	3	2019–2019
Lewis v. Commissioner of Correction green connappct · 2005	3	2007–2017
Ostolaza v. Warden green conn · 1992	3	1994–2013
State v. Buster green conn · 1992	3	1994–2013
Williams v. Commissioner of Correction neutral conn · 2012	3	2012–2013
Carter v. Commissioner of Correction neutral conn · 2012	3	2012–2013
Niver v. Commissioner of Correction green connappct · 2007	3	2007–2013
Johnson v. Commissioner of Correction green conn · 1995	3	2005–2010
State v. Varszegi green conn · 1995	3	2005–2010
Johnson v. Commissioner of Correction green connappct · 1995	3	2005–2010
Sekou v. Warden green conn · 1990	3	1992–2007
Quintana v. Warden green conn · 1991	3	1991–1998
Crenshaw v. Commissioner of Correction neutral connappct · 2022	2	2024–2025
Jordan v. Commissioner of Correction green conn · 2021	2	2024–2024
Alexander, Zelmanski, Danner & Fioritto, PLLC v. Haddad green scotus · 2013	2	2016–2023
White v. United States green scotus · 2013	2	2016–2023
Lafler v. Cooper green scotus · 2012	2	2018–2022
Kellman v. Commissioner of Correction green connappct · 2017	2	2019–2022
Sewell v. Comm'r of Corr. green conn · 2017	2	2021–2022
Holloway v. Commissioner of Correction green connappct · 2013	2	2015–2022
Sewell v. Commissioner of Correction neutral connappct · 2016	2	2021–2022

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 53a-54a (53) CT § Conn. Gen. Stat. § 52-470 (28) CT § Conn. Gen. Stat. § 53-21 (26) CT § Conn. Gen. Stat. § 53a-48 (26) CT § Conn. Gen. Stat. § 53a-49 (25) CT § Conn. Gen. Stat. § 53a-59 (24) CT § Conn. Gen. Stat. § 53a-134 (23) CT § Conn. Gen. Stat. § 53a-70 (23) CT § Conn. Gen. Stat. § 53a-54c (18) CT § Conn. Gen. Stat. § 29-35 (15) CT § Conn. Gen. Stat. § 53a-217 (13) CT § Conn. Gen. Stat. § 53a-92 (13)

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

TX 2963 (1984–2026) IL 2140 (1978–2026) TN 1517 (1989–2026) OH 1079 (1987–2026) GA 1067 (1986–2026) NJ 663 (1987–2026) MO 431 (1958–2025) MS 393 (1984–2026) FL 390 (1985–2026) PA 367 (1987–2026) IN 309 (1985–2025) CT 300 (1989–2026) WI 227 (1972–2026) WA 200 (1986–2026) DE 193 (1988–2026) MT 192 (1986–2026) CA 186 (1987–2026) UT 178 (1987–2026) AR 175 (1986–2026) ID 162 (1986–2026) CO 132 (1987–2026) IA 129 (1987–2026) AL 124 (1985–2026) ND 114 (1987–2025) LA 107 (1992–2026) KS 106 (1992–2025) AZ 106 (1984–2026) MN 103 (1986–2026) NC 95 (1985–2026) MI 85 (1988–2026) KY 83 (1985–2026) OK 78 (1986–2026) DC 73 (1984–2026) NE 70 (1988–2025) NY 67 (1985–2026) MD 65 (1987–2026) RI 51 (1987–2024) SC 50 (1987–2025) ME 48 (1997–2026) NV 43 (1994–2024) VA 40 (1987–2025) SD 38 (1987–2024) NM 37 (1993–2022) WY 36 (1987–2025) WV 35 (1995–2024) VT 20 (1992–2026) MA 9 (1990–2025) NH 8 (1987–2020) HI 5 (1986–2020) AK 4 (2019–2025) VI 4 (2007–2010) GU 3 (2023–2025) OR 3 (2013–2022)

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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