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

5 Massachusetts opinions name it 3 courts 1982–2020 0 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 (7)

CaseFollowedCited
Commonwealth v. Swiftgreen
mass · 1980 · cited in 2 Massachusetts opinions naming this issue, 1999–2001
2 sentences

1999Furthermore, “[t]he defendant’s affirmative response to the facts as stated by another, if those facts contain the necessary elements of the crime, is sufficient to satisfy the Henderson test.” Id.; see also Commonwealth v. Swift, 382 Mass. 78, 84 (1980).

1999Furthermore, “[t]he defendant’s affirmative response to the facts as stated by another, if those facts contain the necessary elements of the crime, is sufficient to satisfy the Henderson test.” Id.; see also Commonwealth v. Swift, 382 Mass. 78, 84 (1980).

22
Commonwealth v. Soffengreen
mass · 1979 · cited in 2 Massachusetts opinions naming this issue, 1986–2001
2 sentences

2001“The defendant’s affirmative response to the facts as stated by another, if those facts contain the neces sary elements of the crime[ 10 ], is sufficient to satisfy the Henderson test.” Ibid., citing Commonwealth v. Soffen, 377 Mass. 433, 442 (1979).

2001“The defendant’s affirmative response to the facts as stated by another, if those facts contain the neces sary elements of the crime[ 10 ], is sufficient to satisfy the Henderson test.” Ibid., citing Commonwealth v. Soffen, 377 Mass. 433, 442 (1979).

22
Commonwealth v. Willisgreen
mass · 1993 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
1 sentence

2020Moreover, as already mentioned, at the time of the stop, Henderson did not know of the defendant's prior OUI convictions and thus Henderson could not have known that the defendant was committing a felony. 7 found, however, Henderson's stop of the defendant did not rise to the level of an arrest. "[W]hether [an] encounter was an arrest or 'merely' a stop . . . depends on the proportional relationship of the degree of intrusiveness on the defendant to the degree of suspicion that prompted the intrusion." Commonwealth v. Willis, 415 Mass. 814, 819 (1993).

11
Commonwealth v. Manhagreen
mass · 2018 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
1 sentence

2020"If an officer exceeds the scope of an investigatory stop, the seizure becomes an arrest." Commonwealth v. Manha, 479 Mass. 44, 48 (2018).

11
Commonwealth v. Huotgreen
mass · 1980 · cited in 1 Massachusetts opinions naming this issue, 1982–1982
1 sentence

1982When a defendant pleads guilty to murder in the second degree the Henderson standard is met either when the defendant admits facts “constituting the essential elements, including the unexplained element of malice aforethought,” Commonwealth v. Huot, 380 Mass. 403, 408 (1980), or when a factual basis for the guilty plea has been shown by “other factual presentation made before the plea is accepted by the judge,” Commonwealth v. Morrow, 363 Mass. 601, 608 (1973).

11
Commonwealth v. Morrowgreen
mass · 1973 · cited in 1 Massachusetts opinions naming this issue, 1982–1982
1 sentence

1982When a defendant pleads guilty to murder in the second degree the Henderson standard is met either when the defendant admits facts “constituting the essential elements, including the unexplained element of malice aforethought,” Commonwealth v. Huot, 380 Mass. 403, 408 (1980), or when a factual basis for the guilty plea has been shown by “other factual presentation made before the plea is accepted by the judge,” Commonwealth v. Morrow, 363 Mass. 601, 608 (1973).

11
Commonwealth v. Sullivangreen
mass · 1982 · cited in 1 Massachusetts opinions naming this issue, 1982–1982
1 sentence

1982See also Commonwealth v. Sullivan, 385 Mass. 497, 508 (1982).

11

Distinguished, questioned or overruled (0)

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

Where else courts name it

NJ 37 (2003–2025) CA 24 (1980–2026) TX 14 (2002–2025) PA 13 (2006–2022) OH 10 (1994–2026) IN 9 (1988–2018) IL 9 (2004–2018) AL 9 (1984–2025) GA 7 (1999–2023) MS 7 (1977–2017) WA 7 (1996–2026) TN 7 (1980–2016) VA 6 (1988–2025) AZ 6 (1978–2023) MA 5 (1982–2020) SC 3 (1988–2026) MD 3 (2009–2018) MO 3 (1992–2013) AR 3 (1995–2022) NE 3 (2014–2018) DC 3 (1985–2024) KS 3 (2019–2020) LA 3 (1987–2016) IA 2 (1994–2016) WV 2 (1986–1992) FL 2 (1996–2007) MI 2 (2003–2015)

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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