inadequate inquiry (District of Columbia) · Go Syfert
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inadequate inquiry in District of Columbia

6 District of Columbia opinions name it 1 courts 1976–2025 1 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 (8)

CaseFollowedCited
Monroe v. United Statesgreen
dc · 1978 · cited in 2 District of Columbia opinions naming this issue, 2004–2013
2 sentences

2004On this record I would hold that the trial court did not meet its "obligation to question defense counsel directly, on the record, about the specifics of [appellant's] complaint." Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . "[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry" —or an inadequate inquiry, as in this case—"this court will remand for findings on the issue." McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) ("In th

2004On this record I would hold that the trial court did not meet its “obligation to question defense counsel directly, on the record, about the specifics of [appellant’s] complaint.” Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . “[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry”— or an inadequate inquiry, as in this case— “this court will remand for findings on the issue.” McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) (“In t

22
State v. Funkgreen
wis · 2011 · cited in 1 District of Columbia opinions naming this issue, 2025–2025
1 sentence

2025The statement Sonmez had made at that point (which her editors had pre-approved) did not state a position on a 62 See Hill, 578 A.2d at 376 (discussing long-held prejudices that women who complained about rape were deranged, emotional, and untrustworthy and therefore needed additional examination and stringent timeliness requirements when making claims against assailants); cf. State v. Funk, 799 N.W.2d 421, 436 (Wisc. 2011) (explaining that “the fact that a juror has been a victim of sexual assault does not make him or her per se biased against the defendant in a sexual assault case”); see als

11
Abshire v. Stategreen
fla · 1994 · cited in 1 District of Columbia opinions naming this issue, 2025–2025
1 sentence

2025The statement Sonmez had made at that point (which her editors had pre-approved) did not state a position on a 62 See Hill, 578 A.2d at 376 (discussing long-held prejudices that women who complained about rape were deranged, emotional, and untrustworthy and therefore needed additional examination and stringent timeliness requirements when making claims against assailants); cf. State v. Funk, 799 N.W.2d 421, 436 (Wisc. 2011) (explaining that “the fact that a juror has been a victim of sexual assault does not make him or her per se biased against the defendant in a sexual assault case”); see als

11
State v. Hillgreen
nj · 1990 · cited in 1 District of Columbia opinions naming this issue, 2025–2025
1 sentence

2025The statement Sonmez had made at that point (which her editors had pre-approved) did not state a position on a 62 See Hill, 578 A.2d at 376 (discussing long-held prejudices that women who complained about rape were deranged, emotional, and untrustworthy and therefore needed additional examination and stringent timeliness requirements when making claims against assailants); cf. State v. Funk, 799 N.W.2d 421, 436 (Wisc. 2011) (explaining that “the fact that a juror has been a victim of sexual assault does not make him or her per se biased against the defendant in a sexual assault case”); see als

11
McFadden v. United Statesgreen
dc · 1992 · cited in 1 District of Columbia opinions naming this issue, 2004–2004
2 sentences

2004On this record I would hold that the trial court did not meet its "obligation to question defense counsel directly, on the record, about the specifics of [appellant's] complaint." Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . "[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry" —or an inadequate inquiry, as in this case—"this court will remand for findings on the issue." McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) ("In th

2004On this record I would hold that the trial court did not meet its “obligation to question defense counsel directly, on the record, about the specifics of [appellant’s] complaint.” Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . “[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry”— or an inadequate inquiry, as in this case— “this court will remand for findings on the issue.” McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) (“In t

11
Matthews v. United Statesgreen
dc · 1993 · cited in 1 District of Columbia opinions naming this issue, 2004–2004
2 sentences

2004On this record I would hold that the trial court did not meet its "obligation to question defense counsel directly, on the record, about the specifics of [appellant's] complaint." Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . "[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry" —or an inadequate inquiry, as in this case—"this court will remand for findings on the issue." McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) ("In th

2004On this record I would hold that the trial court did not meet its “obligation to question defense counsel directly, on the record, about the specifics of [appellant’s] complaint.” Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . “[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry”— or an inadequate inquiry, as in this case— “this court will remand for findings on the issue.” McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) (“In t

11
Briggs v. Zotos International, Inc.green
vaed · 1973 · cited in 1 District of Columbia opinions naming this issue, 1985–1985
1 sentence

1985Briggs v. Zotos International, Inc., 357 F.Supp. 89, 91 (ED.Va.1978).

11
Adams v. United States Ex Rel. McCanngreen
scotus · 1943 · cited in 1 District of Columbia opinions naming this issue, 1976–1976
2 sentences

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Nelson v. United States green
dc · 1991
2 sentences

2004On this record I would hold that the trial court did not meet its "obligation to question defense counsel directly, on the record, about the specifics of [appellant's] complaint." Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . "[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry" —or an inadequate inquiry, as in this case—"this court will remand for findings on the issue." McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) ("In th

2004On this record I would hold that the trial court did not meet its “obligation to question defense counsel directly, on the record, about the specifics of [appellant’s] complaint.” Nelson, 601 A.2d at 592 ; see Monroe, 389 A.2d at 821 . “[W]hen a defendant requests new counsel, based on pretrial ineffectiveness ... and the trial court conducts no inquiry”— or an inadequate inquiry, as in this case— “this court will remand for findings on the issue.” McFadden v. United States, 614 A.2d 11, 17 (D.C.1992) (citations omitted); accord, Matthews v. United States, 629 A.2d 1185, 1193 (D.C.1993) (“In t

12004–2004
Boyd v. United States green
dc · 1991
1 sentence

1998As a “prophylactic colloquy,” id. at 679-80 n. 19, Boyd advocates, but does not mandate, that trial courts question a nontestifying defendant at trial in order to confirm on the record at that point that he or she has fully waived the right to testify, and thus to preempt any post-trial challenges to the waiver.

11998–1998
United States v. George v. Arlen green
ca2 · 1958
1 sentence

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

11976–1976
United States v. Birrell green
nysd · 1968
1 sentence

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

11976–1976
cluster 257306 green
ca5 · 1962
1 sentence

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

11976–1976
Wilbur M. Cleveland v. United States green
cadc · 1963
1 sentence

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

11976–1976
Hess v. Kriz green
scotus · 1963
1 sentence

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

11976–1976
Moon v. United States green
scotus · 1963
1 sentence

1976Glenn v. United States, 303 F.2d 536 (5th Cir. 1962); United States v. Arlen, 252 F.2d 491 (2d Cir. 1958); see Adams v. United States, 317 U.S. 269, 279 , 63 S.Ct. 236 , 87 L.Ed. 268 (1942); Cleveland v. United States, 116 U.S.App.D.C. 188 , 322 F.2d 401 , cert. denied, 375 U.S. 884 , 84 S.Ct. 157 , 11 L.Ed.2d 114 (1963); United States v. Birrell, 286 F.Supp. 885 (S.D.N.Y.1968). 3 We therefore turn to the record to ascertain whether appellant’s conduct was such as to amount to a waiver of his right to counsel at his trial.

11976–1976

Where else courts name it

CA 43 (1954–2026) NJ 33 (1979–2026) IL 29 (1981–2026) OH 22 (1991–2024) WA 21 (1972–2025) PA 21 (1938–2025) FL 19 (1974–2026) MS 17 (1993–2017) TX 17 (1971–2021) ME 14 (1983–2018) CT 10 (1992–2021) NY 9 (1925–2024) NM 9 (1965–2023) IN 9 (1977–2015) NV 8 (1985–2017) IA 8 (1968–2017) WI 8 (1986–2024) OR 8 (1996–2024) MD 7 (1974–2018) AZ 7 (1964–2024) LA 6 (1989–2018) MA 6 (1978–2023) MN 6 (1985–2024) OK 6 (1969–2022) DC 6 (1976–2025) UT 5 (1994–2025) SD 4 (2005–2016) MI 4 (1979–2020) VT 4 (1996–2007) KS 4 (1992–2022) MO 4 (1961–2011) CO 4 (1980–2025) TN 3 (2010–2016) GA 2 (1986–2019) ND 2 (1980–1980) MT 2 (2011–2017) SC 2 (2003–2003) KY 2 (2022–2023) HI 2 (1995–2014) NC 2 (1993–2003) ID 2 (2012–2013)

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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