Strickland prejudice inquiry (Missouri) · Go Syfert
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Strickland prejudice inquiry in Missouri

6 Missouri opinions name it 2 courts 2002–2024 3 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 (3)

CaseFollowedCited
Deck v. Stategreen
mo · 2002 · cited in 2 Missouri opinions naming this issue, 2002–2022
2 sentences

2022However, in the following sentence, the motion court elaborated: “There is no reasonable probability the jury would have returned a different verdict.” Later, the motion court’s judgment stated that the refusal to submit a self-defense instruction based on the castle doctrine was “not outcome determinative.” Sanders argues that, in Deck v. State, 68 S.W.3d 418 (Mo. banc 2002), the Missouri Supreme Court reaffirmed the distinction between the showing of prejudice necessary to justify 18 reversal with respect to plain error on direct appeal and the showing required under Strickland, such that a

2022See id. at 427-28 (noting that Strickland rejected an outcome determinative test).

22
Michael White v. Charles Ryangreen
ca9 · 2018 · cited in 1 Missouri opinions naming this issue, 2020–2020
1 sentence

2020See also White v. Ryan, 895 F.3d 641 (9th Cir. 2018) (concluding that state court’s “prejudice determination was contrary to Strickland” where “the court determined whether it would have imposed a death penalty if it had considered the mitigation evidence that McVay failed to present.

11
Mose Young v. Michael Bowersox, Superintendent, Potosi Correctional Centergreen
ca8 · 1998 · cited in 1 Missouri opinions naming this issue, 2015–2015
1 sentence

2015The Missouri Supreme Court held that the Strickland prejudice standard applied to the movant’s claim, even though the Court recognized that showing a reasonable probability of a different outcome might well be impossible where qualified venire-persons were improperly excluded from a jury. 263 S.W.3d at 648 (quoting Young v. Bowersox, 161 F.3d 1159, 1160-61 (8th Cir.1998)).

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 (3)

CaseCitedYears
Strickland v. Washington green
scotus · 1984
2 sentences

2024Id. at 703 . 82.

2022Without a finding of abandonment 2 See Strickland v. Washington, 466 U.S. 668 (1984). 4 by appointed counsel, the motion court lacked the authority to address the merits of the untimely amended motion.

22022–2024
Saranchak v. Beard green
ca3 · 2010
2 sentences

2020Similarly, in Saranchak v. Beard, 616 F.3d 292 (3d Cir. 2010), the Third Circuit held that a state court had improperly conducted a Strickland prejudice inquiry, where the state court “highlight[ed] the fact that the [post-conviction relief] judge was also the judge” at trial, and erroneously “consider[ed] the effect the new evidence would have had on that particular judge . . . rather than considering, more abstractly, the effect the same evidence would have had on an unspecified, objective factfinder, as required by Strickland.” Id. at 309 .

2020Similarly, in Saranchak v. Beard, 616 F.3d 292 (3d Cir. 2010), the Third Circuit held that a state court had improperly conducted a Strickland prejudice inquiry, where the state court “highlight[ed] the fact that the [post-conviction relief] judge was also the judge” at trial, and erroneously “consider[ed] the effect the new evidence would have had on that particular judge . . . rather than considering, more abstractly, the effect the same evidence would have had on an unspecified, objective factfinder, as required by Strickland.” Id. at 309 .

12020–2020
Strong v. State green
mo · 2008
1 sentence

2015The Missouri Supreme Court held that the Strickland prejudice standard applied to the movant’s claim, even though the Court recognized that showing a reasonable probability of a different outcome might well be impossible where qualified venire-persons were improperly excluded from a jury. 263 S.W.3d at 648 (quoting Young v. Bowersox, 161 F.3d 1159, 1160-61 (8th Cir.1998)).

12015–2015

Where else courts name it

TX 21 (2009–2024) FL 16 (1998–2025) PA 15 (2002–2026) WA 10 (2010–2024) MD 10 (2001–2025) WI 8 (2012–2025) CO 8 (2009–2026) ID 8 (1996–2018) IA 8 (2006–2021) UT 7 (2015–2026) MO 6 (2002–2024) CA 4 (2005–2026) CT 4 (2005–2024) TN 3 (2008–2025) DC 3 (1999–2023) MI 3 (2017–2025) NY 3 (1992–2010) SC 3 (2023–2025) DE 2 (2023–2024) AZ 2 (2007–2026) GA 2 (2014–2020) OH 2 (2024–2026) KS 2 (2007–2020) VA 2 (2002–2005) IN 2 (1996–2016) IL 2 (2021–2024) OK 2 (2023–2025)

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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