innocence requirement (Missouri) · Go Syfert
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innocence requirement in Missouri

6 Missouri opinions name it 2 courts 2010–2024 1 in the last five years

The cases below were cited by Missouri 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
Howarth v. State, Public Defender Agencygreen
alaska · 1996 · cited in 1 Missouri opinions naming this issue, 2013–2013
1 sentence

2013See, e.g., Howarth v. State Public Defender Agency, 925 P.2d 1330, 1332-33 (Alaska 1996) (holding that the legal cause of the plaintiff's sentence was his own intentional criminal conduct, despite the fact that his defense attorney’s conduct as to sentencing was negligent); Lynch v. Warwick, 95 Cal.App.4th 267 , 115 Cal.Rptr.2d 391, 397 (2002) (holding that "the actual innocence requirement for a criminal legal malpractice cáse applies regardless of whether the former criminal defendant is seeking damages for a wrongful conviction, a longer sentence, or for attorney fees”); Paulsen v. Cochran,

11
Paulsen v. Cochrangreen
illappct · 2005 · cited in 1 Missouri opinions naming this issue, 2013–2013
2 sentences

2013See, e.g., Howarth v. State Public Defender Agency, 925 P.2d 1330, 1332-33 (Alaska 1996) (holding that the legal cause of the plaintiff's sentence was his own intentional criminal conduct, despite the fact that his defense attorney’s conduct as to sentencing was negligent); Lynch v. Warwick, 95 Cal.App.4th 267 , 115 Cal.Rptr.2d 391, 397 (2002) (holding that "the actual innocence requirement for a criminal legal malpractice cáse applies regardless of whether the former criminal defendant is seeking damages for a wrongful conviction, a longer sentence, or for attorney fees”); Paulsen v. Cochran,

2013See, e.g., Howarth v. State Public Defender Agency, 925 P.2d 1330, 1332-33 (Alaska 1996) (holding that the legal cause of the plaintiff's sentence was his own intentional criminal conduct, despite the fact that his defense attorney’s conduct as to sentencing was negligent); Lynch v. Warwick, 95 Cal.App.4th 267 , 115 Cal.Rptr.2d 391, 397 (2002) (holding that "the actual innocence requirement for a criminal legal malpractice cáse applies regardless of whether the former criminal defendant is seeking damages for a wrongful conviction, a longer sentence, or for attorney fees”); Paulsen v. Cochran,

11
Lynch v. Warwickgreen
calctapp · 2002 · cited in 1 Missouri opinions naming this issue, 2013–2013
2 sentences

2013See, e.g., Howarth v. State Public Defender Agency, 925 P.2d 1330, 1332-33 (Alaska 1996) (holding that the legal cause of the plaintiff's sentence was his own intentional criminal conduct, despite the fact that his defense attorney’s conduct as to sentencing was negligent); Lynch v. Warwick, 95 Cal.App.4th 267 , 115 Cal.Rptr.2d 391, 397 (2002) (holding that "the actual innocence requirement for a criminal legal malpractice cáse applies regardless of whether the former criminal defendant is seeking damages for a wrongful conviction, a longer sentence, or for attorney fees”); Paulsen v. Cochran,

2013See, e.g., Howarth v. State Public Defender Agency, 925 P.2d 1330, 1332-33 (Alaska 1996) (holding that the legal cause of the plaintiff's sentence was his own intentional criminal conduct, despite the fact that his defense attorney’s conduct as to sentencing was negligent); Lynch v. Warwick, 95 Cal.App.4th 267 , 115 Cal.Rptr.2d 391, 397 (2002) (holding that "the actual innocence requirement for a criminal legal malpractice cáse applies regardless of whether the former criminal defendant is seeking damages for a wrongful conviction, a longer sentence, or for attorney fees”); Paulsen v. Cochran,

11
Belford v. McHale Cook & Welchgreen
indctapp · 1995 · cited in 1 Missouri opinions naming this issue, 2013–2013
1 sentence

2013See, e.g., Howarth v. State Public Defender Agency, 925 P.2d 1330, 1332-33 (Alaska 1996) (holding that the legal cause of the plaintiff's sentence was his own intentional criminal conduct, despite the fact that his defense attorney’s conduct as to sentencing was negligent); Lynch v. Warwick, 95 Cal.App.4th 267 , 115 Cal.Rptr.2d 391, 397 (2002) (holding that "the actual innocence requirement for a criminal legal malpractice cáse applies regardless of whether the former criminal defendant is seeking damages for a wrongful conviction, a longer sentence, or for attorney fees”); Paulsen v. Cochran,

11
Brock v. Stategreen
moctapp · 2007 · cited in 1 Missouri opinions naming this issue, 2011–2011
1 sentence

2011Requesting an instruction for second-degree tampering would have been inconsistent with his innocence defense, and counsel “had no duty to request an instruction that would undermine the entire theory of the case presented at trial.” Brock v. State, 242 S.W.3d 430, 434 (Mo.App.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Strickland v. Washington green
scotus · 1984
1 sentence

2024Id. at 703 . 82.

12024–2024
Kuehne v. Hogan green
moctapp · 2010
2 sentences

2018The Kuehne court found "that the public policy concerns underlying the actual innocence requirement in the context of a malpractice suit against a criminal trial attorney apply equally to cases involving a criminal defendant's post-conviction counsel." Id. at 342 .

2018The Kuehne court concluded that the defendant's "innocence of the criminal charges for which he was convicted [was] essential to satisfy the causation element of his claim." Id.

12018–2018
Ex Parte Robbins green
texcrimapp · 2011
1 sentence

2015Id. at 457-58 .

12015–2015
Schlup v. Delo red
scotus · 1995
2 sentences

2015In Schlup , the United States Supreme Court broadly described “new evidence” in the context of an actual innocence claim 24 as “new reliable evidence — whether it be exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence — that was not presented at trial.” 513 U.S. at 324 , 115 S.Ct. 851 (emphasis added).

2015In Schlup , the United States Supreme Court broadly described “new evidence” in the context of an actual innocence claim 24 as “new reliable evidence — whether it be exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence — that was not presented at trial.” 513 U.S. at 324 , 115 S.Ct. 851 (emphasis added).

12015–2015
Tallmadge v. Boyle green
wisctapp · 2007
2 sentences

2010Id.

2010Id.

12010–2010

Where else courts name it

IL 356 (2004–2026) PA 105 (2010–2026) TX 67 (1995–2025) WA 27 (2001–2025) CA 27 (2000–2026) CT 25 (1994–2026) IA 17 (2016–2025) DE 16 (1994–2025) NV 13 (2011–2022) KS 13 (1993–2024) NY 12 (2014–2025) TN 10 (2000–2015) OR 8 (2018–2026) ID 7 (2011–2026) NM 6 (2007–2025) OH 6 (2005–2025) MO 6 (2010–2024) VA 6 (2006–2025) KY 6 (2020–2023) ME 5 (2010–2020) WI 4 (1997–2025) MA 4 (1993–2010) VT 4 (2006–2012) MT 3 (1976–2013) FL 3 (2009–2016) NJ 3 (2001–2018) MS 3 (2007–2025) AZ 2 (2016–2025) AR 2 (1990–2003) WV 2 (2009–2011) IN 2 (2013–2016) CO 2 (2008–2025) MD 2 (2014–2017) LA 2 (2016–2020) MI 2 (2016–2022) NH 2 (1999–2008) NE 2 (2016–2022)

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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