Case Citator › United States v. Cronic

United States v. Cronic

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
466 U.S. 648
Decided
Confirmed treatments
1
Flagged citations read
264 of 264
Citing cases (total)
6,380
Treatment dates
2017
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. United States v. Cronic is limited in one setting: an Ohio appeals court required proof of prejudice when counsel was absent from a post-sentence plea withdrawal hearing. All 264 flagged citations have been read, and the confirmed limitation is listed below.
More on how this was screened

Other courts applied Cronic's narrow rules for presuming prejudice, cited it approvingly, or discussed other authorities. One lower court reported that Satterwhite v. Texas qualified the critical-stage presumption; that report was not the lower court's own treatment of Cronic.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

6,380 later cases cite United States v. Cronic; 264 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United States v. Cronic?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The court required proof of prejudice for absence of counsel at a post-sentence plea withdrawal hearing, despite recognizing Cronic's presumption for denial of counsel at a critical stage of trial.

    State v. Bradford · Ohio Court of Appeals, Fourth District · filed

    Although a plea withdrawal hearing has been held to be a “critical stage” of a criminal prosecution, a demonstration of prejudice is still required. ... United States v. Cronic, 466 U.S. 648, 659, 104 S.Ct. 2039 (1984) (“[t]he presumption that counsel's assistance is essential [for a fair trial] requires us to conclude that a trial is unfair if the accused is denied counsel at a critical stage of his trial”). ... However, per Taylor, the absence of actual or constructive legal representation in this context, is subject to harmless error analysis. ... Accordingly, a demonstration of prejudice is required in the present case.
    Read the full opinion on CourtListener →

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