Strickland standard in Hawaii

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010Briones, 74 Haw. at 462 , 848 P.2d at 976 (“We have declined, however, to adopt the federal standard for reviewing trial counsel’s performance.” (Citation omitted.)); Smith, 68 Haw. at 310 n. 7, 712 P.2d at 500 n. 7 (criticizing the Strickland test as being “unduly difficult for a defendant to meet.”).

2010Briones, 74 Haw. at 462 , 848 P.2d at 976 (“We have declined, however, to adopt the federal standard for reviewing trial counsel’s performance.” (Citation omitted.)); Smith, 68 Haw. at 310 n. 7, 712 P.2d at 500 n. 7 (criticizing the Strickland test as being “unduly difficult for a defendant to meet.”).

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010Juvenile Department of Multnomah County v. Geist, 310 Or. 176 , 796 P.2d 1193, 1204 (1990), which required a mother whose parental rights were terminated to show “not only that her trial counsel was inadequate, but also that any inadequacy prejudiced her cause to the extent that she was denied a fair trial and, therefore, that the justice of the circuit court’s decision is called into serious question.” In declining to apply the Strickland standard, the Geist court distinguished juvenile court proceedings from adult criminal proceedings, noting that “[tjhere simply is no compelling reason that

2010Juvenile Department of Multnomah County v. Geist, 310 Or. 176 , 796 P.2d 1193, 1204 (1990), which required a mother whose parental rights were terminated to show “not only that her trial counsel was inadequate, but also that any inadequacy prejudiced her cause to the extent that she was denied a fair trial and, therefore, that the justice of the circuit court’s decision is called into serious question.” In declining to apply the Strickland standard, the Geist court distinguished juvenile court proceedings from adult criminal proceedings, noting that “[tjhere simply is no compelling reason that

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010(Citing Strickland [].))); In re R.G., 165 Ill.App.3d 112 , 116 Ill.Dec. 69 , 518 N.E.2d 691 , 700-01 (1988) (“[W]hether respondent shall prevail on her claim that she was deprived of her right to the effective assistance of counsel is guided by the standards set out in Strickland [], and adopted by our supreme court in People v. Albanese[, 104 Ill.2d 504 , 85 Ill.Dec. 441 ,] 473 N.E.2d 1246 [, 1255 (Ill.1984) ].”); In re D.W., 385 N.W.2d 570, 579 (Iowa 1986) (“Although the sixth amendment is not implicated here, we nonetheless will apply the same standards adopted for counsel appointed in a c

2010Juvenile Department of Multnomah County v. Geist, 310 Or. 176 , 796 P.2d 1193, 1204 (1990), which required a mother whose parental rights were terminated to show “not only that her trial counsel was inadequate, but also that any inadequacy prejudiced her cause to the extent that she was denied a fair trial and, therefore, that the justice of the circuit court’s decision is called into serious question.” In declining to apply the Strickland standard, the Geist court distinguished juvenile court proceedings from adult criminal proceedings, noting that “[tjhere simply is no compelling reason that

2010Juvenile Department of Multnomah County v. Geist, 310 Or. 176 , 796 P.2d 1193, 1204 (1990), which required a mother whose parental rights were terminated to show “not only that her trial counsel was inadequate, but also that any inadequacy prejudiced her cause to the extent that she was denied a fair trial and, therefore, that the justice of the circuit court’s decision is called into serious question.” In declining to apply the Strickland standard, the Geist court distinguished juvenile court proceedings from adult criminal proceedings, noting that “[tjhere simply is no compelling reason that

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010Dep’t of Human Servs., 361 Ark. 164 , 205 S.W.3d 778, 794 (2005) (adopting the federal criminal “standard for ineffectiveness set out in Strickland [v. Washington, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ]”); In re V.M.R., 768 P.2d 1268, 1270 (Colo.Ct.App.1989) (holding that the Strickland standard applied to non-criminal eases such as parental termination cases); State v. Anonymous, 179 Conn. 155 , 425 A.2d 939, 943 (1979) (adopting the Connecticut criminal standard for ineffective assistance of counsel enunciated in Buckley v. Warden, 177 Conn. 538 , 418 A.2d 913, 916 (1979));

2010Briones, 74 Haw. at 462 , 848 P.2d at 976 (“We have declined, however, to adopt the federal standard for reviewing trial counsel’s performance.” (Citation omitted.)); Smith, 68 Haw. at 310 n. 7, 712 P.2d at 500 n. 7 (criticizing the Strickland test as being “unduly difficult for a defendant to meet.”).

2010Briones, 74 Haw. at 462 , 848 P.2d at 976 (“We have declined, however, to adopt the federal standard for reviewing trial counsel’s performance.” (Citation omitted.)); Smith, 68 Haw. at 310 n. 7, 712 P.2d at 500 n. 7 (criticizing the Strickland test as being “unduly difficult for a defendant to meet.”).