prophylactic rule (Vermont) · Go Syfert
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prophylactic rule in Vermont

5 Vermont opinions name it 1 courts 1986–2017 0 in the last five years

The cases below were cited by Vermont 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 (3)

CaseFollowedCited
Currier v. Letourneaugreen
vt · 1977 · cited in 1 Vermont opinions naming this issue, 2011–2011
2 sentences

2011To serve this goal, we found it fair to have the broker bear the risk of his or her failure to obtain a written listing agreement, and to apply “a prophylactic rule under which a broker without a written listing agreement cannot recover a commission.” Id.; Currier, 135 Vt. at 200 , 373 A.2d at 525 (stating that the law on the question is “unequivocal; a duly executed listing agreement is the sole vehicle upon which a broker can predicate recovery of any commission”). ¶ 26.

2011To serve this goal, we found it fair to have the broker bear the risk of his or her failure to obtain a written listing agreement, and to apply “a prophylactic rule under which a broker without a written listing agreement cannot recover a commission.” Id.; Currier, 135 Vt. at 200 , 373 A.2d at 525 (stating that the law on the question is “unequivocal; a duly executed listing agreement is the sole vehicle upon which a broker can predicate recovery of any commission”). ¶ 26.

11
People v. Breamangreen
colo · 1997 · cited in 1 Vermont opinions naming this issue, 2009–2009
2 sentences

2009Absent an underlying constitutional right to counsel in state post-conviction proceedings, there is "no constitutional right to insist on the Anders procedures which were designed solely to protect that underlying constitutional right." Id. at 557, 107 S.Ct. 1990 . " Anders established a prophylactic framework that is relevant when, and only when, a litigant has a previously established constitutional right to counsel." Id. at 555, 107 S.Ct. 1990 ; see also People v. Breaman, 939 P.2d 1348 , 1351 n. 2 (Colo.1997) (en banc) (citing Finley and concluding that appointed attorney who seeks to with

2009“Anders established a prophylactic framework that is relevant when, and only when, a litigant has a previously established constitutional right to counsel.” Id. at 555; see also People v. Breaman, 939 P.2d 1348 , 1351 n.2 (Colo. 1997) (en banc) (citing Finley and concluding that appointed attorney who seeks to withdraw from representing defendant in post-conviction proceeding may inform court that he or she believes defendant’s claims are without merit and request permission to withdraw without filing Anders brief). ¶ 10.

11
Pennsylvania v. Finleygreen
scotus · 1987 · cited in 1 Vermont opinions naming this issue, 2009–2009
2 sentences

2009Absent an underlying constitutional right to counsel in state post-conviction proceedings, there is "no constitutional right to insist on the Anders procedures which were designed solely to protect that underlying constitutional right." Id. at 557, 107 S.Ct. 1990 . " Anders established a prophylactic framework that is relevant when, and only when, a litigant has a previously established constitutional right to counsel." Id. at 555, 107 S.Ct. 1990 ; see also People v. Breaman, 939 P.2d 1348 , 1351 n. 2 (Colo.1997) (en banc) (citing Finley and concluding that appointed attorney who seeks to with

2009“Anders established a prophylactic framework that is relevant when, and only when, a litigant has a previously established constitutional right to counsel.” Id. at 555; see also People v. Breaman, 939 P.2d 1348 , 1351 n.2 (Colo. 1997) (en banc) (citing Finley and concluding that appointed attorney who seeks to withdraw from representing defendant in post-conviction proceeding may inform court that he or she believes defendant’s claims are without merit and request permission to withdraw without filing Anders brief). ¶ 10.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Miranda v. Arizona green
scotus · 1966
2 sentences

2017Miranda , 384 U.S. at 444 , 86 S.Ct. 1602 . *447 ¶ 53.

2017Miranda , 384 U.S. at 444 , 86 S.Ct. 1602 . *447 ¶ 53.

12017–2017
State v. West green
vt · 1995
2 sentences

2003We held that a showing of prejudice was unnecessary because of the nature of the right involved and because a prejudice requirement “would be wholly inconsistent with a prophylactic rule created to ensure that a waiver is informed, voluntary and intekigent.” Id. at 201 , 667 A.2d at 546 .

2003We held that a showing of prejudice was unnecessary because of the nature of the right involved and because a prejudice requirement “would be wholly inconsistent with a prophylactic rule created to ensure that a waiver is informed, voluntary and intekigent.” Id. at 201 , 667 A.2d at 546 .

12003–2003
Solem v. Stumes green
scotus · 1984
1 sentence

1986In Solem v. Stumes, supra, 465 U.S. at 646 , the Court carefully explained that Edwards changed the law for determining waiver of the Miranda right to counsel from one of case-by-case analysis to the application of a prophylactic rule.

11986–1986

Where else courts name it

PA 99 (1966–2025) CA 57 (1978–2025) TX 39 (1983–2023) CT 38 (1984–2025) MI 30 (1976–2024) IL 28 (1983–2025) FL 26 (1980–2024) GA 24 (1981–2026) LA 24 (1979–2020) WI 22 (1980–2021) DC 20 (1978–2015) MA 18 (1975–2015) MD 18 (1981–2025) NJ 17 (1979–2025) IN 15 (1974–2020) NC 14 (1983–2018) NY 13 (1966–2023) MO 13 (1972–2018) IA 13 (1982–2023) AZ 11 (1966–2023) OH 11 (1988–2022) ME 11 (1972–2018) CO 9 (1995–2019) OR 9 (1972–2017) MN 9 (1968–2024) RI 8 (1973–2011) WA 8 (2013–2020) NM 8 (1989–2022) MS 7 (1981–2003) AL 7 (1988–2014) AR 6 (1998–2019) VA 6 (1990–2011) NV 6 (1989–2019) WV 6 (1982–2025) UT 6 (1984–2024) TN 5 (1985–2026) VT 5 (1986–2017) KY 5 (1978–2023) OK 4 (1982–1993) DE 4 (1978–2019) KS 3 (1968–2008) AK 3 (1987–1993) HI 3 (2000–2008) NH 2 (1991–2015) ID 2 (1973–2007) NE 2 (1993–2018) SC 2 (1996–2007) SD 2 (1973–1990)

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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