Cited by
Opinions in Arizona that cite State v. Gerlaugh, 698 P.2d 694.
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State v. Hamilton
Ariz. Ct. App. Div. 1 2026
¶ 8 (App. 2018) (“[D]isagreements about trial strategy will not support an ineffective 5 STATE v. HAMILTON Decision of the Court assistance claim if the challenged conduct has some reasoned basis, even if the tactics counsel adopts are unsuccessful.” (citation modified)); (“Disagreements in trial strategy will not support a claim of ineffective assistance so long as the challenged conduct has some reasoned basis.”).
- State v. Ricci Ariz. Ct. App. Div. 1 2025
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State v. Ricci
Ariz. Ct. App. Div. 1 2025
A strategic decision by counsel generally will not support an ineffective assistance claim unless the decision has no “reasoned basis.”
- State v. Tarr Ariz. Ct. App. Div. 1 2025
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State v. Tarr
Ariz. Ct. App. Div. 1 2025
A strategic decision by counsel will not support an ineffective assistance of counsel claim unless the decision has no “reasoned basis.” see also Strickland v. Washington, 466 U.S. 668, 690– 91 (1984) (“[S]trategic choices made after thorough investigation of law and facts relevant to plausible options are virtually unchallengeable.”).
- State v. Cramer Ariz. Ct. App. Div. 1 2025
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State v. Cramer
Ariz. Ct. App. Div. 1 2025
(“Disagreements in trial strategy will not support a claim of ineffective assistance so long as the challenged conduct has some reasoned basis.” (citations omitted)); see also Pandeli, 242 Ariz. at 182-83, ¶¶ 13-16 (holding that defense counsel was not ineffective by forgoing cross-examination of the State
- In Re Term of Parental Rights as to J.L. Ariz. Ct. App. Div. 1 2025
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In Re Term of Parental Rights as to J.L.
Ariz. Ct. App. Div. 1 2025
Royce C., 252 Ariz. at 136, 138, ¶¶ 20, 25–26; (noting that counsel’s decisions about what evidence and witnesses to present at trial, particularly the cumulative evidence, is a strategic choice that will not support a claim of ineffective assistance of counsel).
- State v. Mello Ariz. Ct. App. Div. 1 2024
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State v. Mello
Ariz. Ct. App. Div. 1 2024
Because we presume "counsel's conduct falls within the wide range of reasonable professional assistance," Strickland, 466 U.S. at 689, "[d]isagreements in trial strategy will not support a claim of ineffective assistance so long as the challenged conduct has some reasoned basis,"
- State v. Rogers Ariz. Ct. App. Div. 1 2024
- State v. Rogers Ariz. Ct. App. Div. 1 2024
- State v. Kashkool Ariz. Ct. App. Div. 1 2024
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State v. Kashkool
Ariz. Ct. App. Div. 1 2024
“Disagreements in trial strategy will not support a claim of ineffective 2 STATE v. KASHKOOL Decision of the Court assistance so long as the challenged conduct has some reasoned basis.”
- State v. Linville Ariz. Ct. App. Div. 1 2022
- State v. Linville Ariz. Ct. App. Div. 1 2022
- State v. Stanley Ariz. Ct. App. Div. 1 2022
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State v. Stanley
Ariz. Ct. App. Div. 1 2022
“Disagreements in trial strategy will not support a claim of ineffective assistance so long as the challenged conduct has some reasoned basis.”
- State of Arizona v. Ronald Bruce Bigger 492 P.3d 1020 Ariz. 2021
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State of Arizona v. Ronald Bruce Bigger
492 P.3d 1020
Ariz. 2021
See, (reasoning that “[d]isagreements in trial strategy will not support a claim of ineffective assistance so long as the challenged conduct has some reasoned basis” (emphasis added)); Pandeli, 242 Ariz. at 183 ¶ 21 (rejecting IAC claim based on failure to cross-examine because it “was a strategic decision that
- State v. Jaime Ariz. Ct. App. Div. 1 2021
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State v. Jaime
Ariz. Ct. App. Div. 1 2021
disapproved of on other grounds, ¶ 25 (2001); 461 (1985) (analyzing attorney’s “failure to argue for petitioner’s alleged intoxication” as trial strategy); (attorney’s decision “as to what witnesses should be called .
- State v. Varela 425 P.3d 267 Ariz. Ct. App. Div. 2 2018
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State v. Varela
425 P.3d 267
Ariz. Ct. App. Div. 2 2018
quoting State v. Gerlaugh , , 455
- State v. Beasley Ariz. Ct. App. Div. 1 2017
- State v. Beasley Ariz. Ct. App. Div. 1 2017
- In Re Nicholas L. Ariz. Ct. App. Div. 1 2015
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In Re Nicholas L.
Ariz. Ct. App. Div. 1 2015
(citing Strickland v. Washington, 466 U.S. 668, 694 (1984)).
- State of Arizona v. Vaughn Miles Denz 306 P.3d 98 Ariz. Ct. App. Div. 2 2013
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State of Arizona v. Vaughn Miles Denz
306 P.3d 98
Ariz. Ct. App. Div. 2 2013
Thus, disagreements about trial strategy will not support an ineffective assistance claim if “the challenged conduct has some reasoned basis,” even if the tactics counsel adopts are unsuccessful.
- In Re Mh2010-002637 263 P.3d 82 Ariz. Ct. App. Div. 1 2011
- In Re Mh2010-002637 263 P.3d 82 Ariz. Ct. App. Div. 1 2011
- State v. Hargrave 234 P.3d 569 Ariz. 2010
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State v. Hargrave
234 P.3d 569
Ariz. 2010
Although youth “is entitled to great weight as a mitigating circumstance,” - 35 - we also consider the defendant’s maturity, judgment, intelligence, and involvement in the crime
- State v. Djerf 959 P.2d 1274 Ariz. 1998
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State v. Djerf
959 P.2d 1274
Ariz. 1998
See, -32 , -50 (1996) (age sixteen not mitigating factor); , (age twenty not mitigating factor); -61 , -06 (1985) (age nineteen not mitigating factor).
- State v. Trostle 951 P.2d 869 Ariz. 1997
- State v. Trostle 951 P.2d 869 Ariz. 1997
- State v. Jackson 918 P.2d 1038 Ariz. 1996
- State v. Jackson 918 P.2d 1038 Ariz. 1996
- State v. Medrano 914 P.2d 225 Ariz. 1996
- State v. Medrano 914 P.2d 225 Ariz. 1996
- State v. Roscoe 910 P.2d 635 Ariz. 1996
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State v. Roscoe
910 P.2d 635
Ariz. 1996
Interference with counsel’s strategy In dealing with a defendant’s request that counsel not present certain mitigating evidence, this court has stated that “an attorney’s decisions concerning representation can properly be influenced by his client’s wishes.” , (citing Strickland v. Washington, 466 U.S. 668, 691 , 104 S.Ct.
- State v. Ray 912 P.2d 1318 Ariz. Ct. App. Div. 1 1995
- State v. Ray 912 P.2d 1318 Ariz. Ct. App. Div. 1 1995
- State v. Bolton 896 P.2d 830 Ariz. 1995
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State v. Bolton
896 P.2d 830
Ariz. 1995
-62 , -07 (1985) (self-serving testimony insufficient to prove intoxication).
- State v. Rosas 904 P.2d 1245 Ariz. Ct. App. Div. 1 1995