alphabet test (Massachusetts) · Go Syfert
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alphabet test in Massachusetts

5 Massachusetts opinions name it 2 courts 1995–2025 2 in the last five years

The cases below were cited by Massachusetts 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 (6)

CaseFollowedCited
Commonwealth v. Greniergreen
massappct · 1998 · cited in 2 Massachusetts opinions naming this issue, 2006–2024
2 sentences

2024In Commonwealth v. Grenier, 45 Mass. App. Ct. 58, 61 (1998), we held that the defendant's statement that "he could not do the one-legged stand test" was inadmissible refusal evidence.

2006In hearing the defendant’s refusal, the jury could have drawn a negative inference, making it “the equivalent of [the] statement, 1 have had so much to drink that I know or at least suspect that I am unable to pass the test.’ ” Commonwealth v. Grenier, 45 Mass. App. Ct. at 61 , quoting from Opinion of the Justices, 412 Mass. at 1209 .

12
Commonwealth v. Sandsgreen
mass · 1997 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025This is because ordinary field sobriety tests "measure a person's sense of balance, coordination, and acuity of mind in Specifically, defense counsel asked, "And is there data or 1 . . . anything that you know of that indicates the accuracy of using the alphabet test to --" and "Officer, if you know do you know . . . what the rate of accuracy is . . . for [the one-leg stand] test to determine if somebody is under the influence?" The Commonwealth objected before defense counsel could finish asking the first question about the alphabet test. 5 understanding and following simple instructions," an

11
Commonwealth v. Mercadogreen
mass · 2010 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025See Mercado, 456 Mass. at 204 (no abuse of discretion in limiting use of photographs in cross-examination where defense counsel thoroughly cross-examined witness on point in question); Commonwealth v. Avalos, 454 Mass. 1, 8 (2009), quoting Commonwealth v. LaVelle, 414 Mass. 146, 154 (1993) (no abuse of discretion in sustaining objections to two questions on cross- examination "because the issue was 'sufficiently aired'"). 3.

11
Commonwealth v. Avalosgreen
mass · 2009 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025See Mercado, 456 Mass. at 204 (no abuse of discretion in limiting use of photographs in cross-examination where defense counsel thoroughly cross-examined witness on point in question); Commonwealth v. Avalos, 454 Mass. 1, 8 (2009), quoting Commonwealth v. LaVelle, 414 Mass. 146, 154 (1993) (no abuse of discretion in sustaining objections to two questions on cross- examination "because the issue was 'sufficiently aired'"). 3.

11
Commonwealth v. LaVellegreen
mass · 1993 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025See Mercado, 456 Mass. at 204 (no abuse of discretion in limiting use of photographs in cross-examination where defense counsel thoroughly cross-examined witness on point in question); Commonwealth v. Avalos, 454 Mass. 1, 8 (2009), quoting Commonwealth v. LaVelle, 414 Mass. 146, 154 (1993) (no abuse of discretion in sustaining objections to two questions on cross- examination "because the issue was 'sufficiently aired'"). 3.

11
Vanhouton v. Commonwealthgreen
mass · 1997 · cited in 1 Massachusetts opinions naming this issue, 2003–2003
1 sentence

2003See Vanhouton v. Commonwealth, 424 Mass. at 335-336 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Commonwealth v. Ranieri green
massappct · 2006
1 sentence

2024In Commonwealth v. Ranieri, 65 Mass. App. Ct. 366 , 370 n.1, 372-373 (2006), we concluded that refusal evidence was improperly admitted at trial where the defendant said "no" when asked to perform the alphabet test even though he subsequently attempted the test.

12024–2024
Opinion of the Justices to the Senate green
mass · 1992
1 sentence

2006In hearing the defendant’s refusal, the jury could have drawn a negative inference, making it “the equivalent of [the] statement, 1 have had so much to drink that I know or at least suspect that I am unable to pass the test.’ ” Commonwealth v. Grenier, 45 Mass. App. Ct. at 61 , quoting from Opinion of the Justices, 412 Mass. at 1209 .

12006–2006
Pennsylvania v. Muniz green
scotus · 1990
1 sentence

1995Like the sixth-birthday question in Pennsylvania v. Muniz, supra, the alphabet test here required a testimonial response. 18 Like Muniz’s truthful answer that he could not correctly state what the date of his sixth birthday was, Van Houtin’s truthfully incorrect recitation of the alphabet supported an inference that his mental faculties were impaired.

11995–1995

Where else courts name it

DE 6 (2011–2024) MA 5 (1995–2025) GA 3 (1989–1992) KS 2 (2009–2020) SD 2 (1989–2002) TX 2 (1991–1996)

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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