tactical error (Alabama) · Go Syfert
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tactical error in Alabama

6 Alabama opinions name it 2 courts 1987–2009 0 in the last five years

The cases below were cited by Alabama 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
Hutchins v. Stategreen
alacrimapp · 1990 · cited in 3 Alabama opinions naming this issue, 2003–2009
2 sentences

2009P.” (C.R. 1087-88.) We agree with the circuit court’s findings. “ ‘An accused is not entitled to error-free counsel.’” Stringfellow v. State, 485 So.2d 1238, 1243 (Ala.Crim.App.1986), quoting Phelps v. State, 439 So.2d 727, 735 (Ala.Crim.App.1983). “ ‘Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.’ ” Hutchins v. State, 568 So.2d 395, 396 (Ala.Crim.App.1990), quoting Ex parte Lawley, 512 So.2d 1370, 1373 (Ala.1987).

2005Because that theory proved unsuccessful does not mean that Glassroth's opinions are conclusive and establish the requirements of Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984). "`Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.' Ex parte Lawley, 512 So.2d 1370 (Ala.1987). `"An accused is not entitled to error-free counsel."' Stringfellow [v. State ], 485 So.2d [1238] at 1243 [(Ala.Crim.App

23
Ex Parte Lawleygreen
ala · 1987 · cited in 4 Alabama opinions naming this issue, 1990–2009
2 sentences

2009P.” (C.R. 1087-88.) We agree with the circuit court’s findings. “ ‘An accused is not entitled to error-free counsel.’” Stringfellow v. State, 485 So.2d 1238, 1243 (Ala.Crim.App.1986), quoting Phelps v. State, 439 So.2d 727, 735 (Ala.Crim.App.1983). “ ‘Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.’ ” Hutchins v. State, 568 So.2d 395, 396 (Ala.Crim.App.1990), quoting Ex parte Lawley, 512 So.2d 1370, 1373 (Ala.1987).

2005Because that theory proved unsuccessful does not mean that Glassroth's opinions are conclusive and establish the requirements of Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984). "`Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.' Ex parte Lawley, 512 So.2d 1370 (Ala.1987). `"An accused is not entitled to error-free counsel."' Stringfellow [v. State ], 485 So.2d [1238] at 1243 [(Ala.Crim.App

14
Stringfellow v. Stategreen
alacrimapp · 1986 · cited in 2 Alabama opinions naming this issue, 1990–2009
2 sentences

2009P.” (C.R. 1087-88.) We agree with the circuit court’s findings. “ ‘An accused is not entitled to error-free counsel.’” Stringfellow v. State, 485 So.2d 1238, 1243 (Ala.Crim.App.1986), quoting Phelps v. State, 439 So.2d 727, 735 (Ala.Crim.App.1983). “ ‘Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.’ ” Hutchins v. State, 568 So.2d 395, 396 (Ala.Crim.App.1990), quoting Ex parte Lawley, 512 So.2d 1370, 1373 (Ala.1987).

1990"Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel." Ex parte Lawley , 512 So.2d 1370 (Ala. 1987). " 'An accused is not entitled to error-free counsel.' " Stringfellow , 485 So.2d at 1243 .

12
Strickland v. Washingtongreen
scotus · 1984 · cited in 2 Alabama opinions naming this issue, 1988–2005
2 sentences

2005Because that theory proved unsuccessful does not mean that Glassroth's opinions are conclusive and establish the requirements of Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984). "`Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.' Ex parte Lawley, 512 So.2d 1370 (Ala.1987). `"An accused is not entitled to error-free counsel."' Stringfellow [v. State ], 485 So.2d [1238] at 1243 [(Ala.Crim.App

2005Because that theory proved unsuccessful does not mean that Glassroth's opinions are conclusive and establish the requirements of Strickland v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984). "`Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.' Ex parte Lawley, 512 So.2d 1370 (Ala.1987). `"An accused is not entitled to error-free counsel."' Stringfellow [v. State ], 485 So.2d [1238] at 1243 [(Ala.Crim.App

12
Phelps v. Stategreen
alacrimapp · 1983 · cited in 1 Alabama opinions naming this issue, 2009–2009
1 sentence

2009P.” (C.R. 1087-88.) We agree with the circuit court’s findings. “ ‘An accused is not entitled to error-free counsel.’” Stringfellow v. State, 485 So.2d 1238, 1243 (Ala.Crim.App.1986), quoting Phelps v. State, 439 So.2d 727, 735 (Ala.Crim.App.1983). “ ‘Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right to counsel.’ ” Hutchins v. State, 568 So.2d 395, 396 (Ala.Crim.App.1990), quoting Ex parte Lawley, 512 So.2d 1370, 1373 (Ala.1987).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Tillis v. State green
ala · 1974
2 sentences

1988Summers v. State , 366 So.2d [336] at 341 [Ala.Cr.App. 1978], citing Tillis v. State , 292 Ala. 521 , 296 So.2d 892 (1974). 'An error by counsel, even if professionally unreasonable, does not warrant setting aside the judgment of a criminal proceeding if the error had no effect on the judgment.' Strickland, supra , 466 U.S. at 691 [ 104 S.Ct. at 2066 ]. '[A]ny deficiencies in counsel's performance must be prejudicial to the defense in order to constitute ineffective assistance under the Constitution.' Strickland , 466 U.S. at 692 [ 104 S.Ct. at 2067 ].

1988Summers v. State , 366 So.2d [336] at 341 [Ala.Cr.App. 1978], citing Tillis v. State , 292 Ala. 521 , 296 So.2d 892 (1974). 'An error by counsel, even if professionally unreasonable, does not warrant setting aside the judgment of a criminal proceeding if the error had no effect on the judgment.' Strickland, supra , 466 U.S. at 691 [ 104 S.Ct. at 2066 ]. '[A]ny deficiencies in counsel's performance must be prejudicial to the defense in order to constitute ineffective assistance under the Constitution.' Strickland , 466 U.S. at 692 [ 104 S.Ct. at 2067 ].

21987–1988
Thompson v. State green
alacrimapp · 1992
1 sentence

2003"An accused is entitled `"not [to] errorless counsel, and not [to] counsel judged ineffective by hindsight, but [to] counsel reasonably likely to render and rendering reasonably effective assistance."'" Dobyne v. State , 805 So.2d at 758 (quoting Thompson v. State , 615 So.2d 129 , 134 (Ala.Crim.App. 1992), quoting in turn Haggard v. Alabama , 550 F.2d 1019 , 1022 (5th Cir. 1977)). "`Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right t

12003–2003
Henry C. Haggard v. State of Alabama green
ca5 · 1977
1 sentence

2003"An accused is entitled `"not [to] errorless counsel, and not [to] counsel judged ineffective by hindsight, but [to] counsel reasonably likely to render and rendering reasonably effective assistance."'" Dobyne v. State , 805 So.2d at 758 (quoting Thompson v. State , 615 So.2d 129 , 134 (Ala.Crim.App. 1992), quoting in turn Haggard v. Alabama , 550 F.2d 1019 , 1022 (5th Cir. 1977)). "`Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right t

12003–2003
Dobyne v. State green
alacrimapp · 2000
1 sentence

2003"An accused is entitled `"not [to] errorless counsel, and not [to] counsel judged ineffective by hindsight, but [to] counsel reasonably likely to render and rendering reasonably effective assistance."'" Dobyne v. State , 805 So.2d at 758 (quoting Thompson v. State , 615 So.2d 129 , 134 (Ala.Crim.App. 1992), quoting in turn Haggard v. Alabama , 550 F.2d 1019 , 1022 (5th Cir. 1977)). "`Even if counsel committed what appears in retrospect to have been a tactical error, that does not automatically mean that petitioner did not receive an adequate defense in the context of the constitutional right t

12003–2003
Summers v. State green
alacrimapp · 1978
1 sentence

1987Summers v. State , 366 So.2d at 341 , citing Tillis v. State , 292 Ala. 521 , 296 So.2d 892 (1974).

11987–1987

Where else courts name it

MA 10 (1997–2018) NY 8 (1934–2020) AL 6 (1987–2009) CA 6 (1972–2024) CO 5 (1980–2002) PA 3 (1979–2016) FL 3 (1986–2011) TX 2 (2002–2015) IL 2 (1979–2020) GA 2 (1997–2023)

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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