lack instruction (Massachusetts) · Go Syfert
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lack instruction in Massachusetts

34 Massachusetts opinions name it 3 courts 1947–2023 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 (30)

CaseFollowedCited
Commonwealth v. Washingtongreen
mass · 2007 · cited in 2 Massachusetts opinions naming this issue, 2012–2018
2 sentences

2018See id.

2012See id. at 489 .

22
Commonwealth v. Morangreen
massappct · 1983 · cited in 2 Massachusetts opinions naming this issue, 1985–2003
2 sentences

1985See Commonwealth v. Appleby, supra at 368 (refusal “to sign a waiver form is not conclusive of a lack of waiver”); Commonwealth v. Cavanaugh, 371 Mass. 46, 54 (1976); Commonwealth v. Moran, 17 Mass. App. Ct. 200, 207 (1983).

1985See Commonwealth v. Appleby, supra at 368 (refusal "to sign a waiver form is not conclusive of a lack of waiver"); Commonwealth v. Cavanaugh, 371 Mass. 46, 54 (1976); Commonwealth v. Moran, 17 Mass. App. Ct. 200, 207 (1983).

22
Commonwealth v. Applebygreen
mass · 1983 · cited in 2 Massachusetts opinions naming this issue, 1983–1985
2 sentences

1985See Commonwealth v. Appleby, supra at 368 (refusal “to sign a waiver form is not conclusive of a lack of waiver”); Commonwealth v. Cavanaugh, 371 Mass. 46, 54 (1976); Commonwealth v. Moran, 17 Mass. App. Ct. 200, 207 (1983).

1985See Commonwealth v. Appleby, supra at 368 (refusal "to sign a waiver form is not conclusive of a lack of waiver"); Commonwealth v. Cavanaugh, 371 Mass. 46, 54 (1976); Commonwealth v. Moran, 17 Mass. App. Ct. 200, 207 (1983).

22
Commonwealth v. Pamplonagreen
massappct · 2003 · cited in 2 Massachusetts opinions naming this issue, 2010–2023
2 sentences

2023Rule 3:10, § 3, because the judge made no written findings and did not certify that the defendant executed the form in her presence, this "is not conclusive of a lack of waiver." Pamplona, 58 Mass. App. Ct. at 243 .

2010Rule 3:10, as amended, 416 Mass. 1306 (1993), is not conclusive of a lack of waiver.” Commonwealth v. Pamplona, 58 Mass. App. Ct. 239, 242-243 (2003).

12
Commonwealth v. Freemangreen
mass · 1967 · cited in 2 Massachusetts opinions naming this issue, 1973–2009
2 sentences

2009See Commonwealth v. Freeman, 352 Mass. 556, 564 (1967).

1973In view of the defendant’s admission on the stand that he had received payments totaling $295, the lack of such an instruction in the charge, albeit on a salient point, did not raise “a substantial risk of a miscarriage of justice” (Commonwealth v. Freeman, 352 Mass. 556, 564 ) so as to impel us to reverse.

12
Commonwealth v. Guntergreen
mass · 1998 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
2 sentences

2023See id. at 119 ; Gunter, supra at 274. ii.

2023See Phap Buth, 480 Mass. at 120 , citing Gunter, 427 Mass. at 274 . c.

11
Commonwealth v. Phap Buthgreen
mass · 2018 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
2 sentences

2023See id. at 119 ; Gunter, supra at 274. ii.

2023See Phap Buth, 480 Mass. at 120 , citing Gunter, 427 Mass. at 274 . c.

11
Commonwealth v. Robertsgreen
mass · 1979 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
1 sentence

2020Although the instructions do not track with precision the Criminal Model Jury Instructions for Use in the District Court (2009) (model instructions), they provided an "adequate and clear instruction[] on the applicable law," Commonwealth v. Roberts, 378 Mass. 116, 130 (1979), S.C., 423 Mass. 17 (1996), and neither the model instructions nor the supplemental instructions contain language about the piling of inferences.

11
Commonwealth v. Richardsongreen
mass · 2018 · cited in 1 Massachusetts opinions naming this issue, 2019–2019
2 sentences

2019See Commonwealth v. Richardson , 479 Mass. 344 , 354-355, 94 N.E.3d 819 (2018). 2.

2019See Commonwealth v. Richardson , 479 Mass. 344 , 354-355, 94 N.E.3d 819 (2018). 2.

11
Commonwealth v. Braungreen
massappct · 2009 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
1 sentence

2015See id. at 645-646 ; Commonwealth v. Braun, 74 Mass. App. Ct. 904, 905-906 (2009).

11
cluster 468096green
ca1 · 1986 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
1 sentence

2015See Laaperi v. Sears, Roebuck & Co., 787 F.2d 726, 729 (1st Cir. 1986) (“the failure to warn of hazards associated with foreseeable uses of a product is itself negligence, and if that negligence proximately results in a plaintiff’s injuries, the plaintiff may recover”; applying Massachusetts law); Jones v. Walter Kidde Portable Equip., 16 F. Supp. 2d 123, 125 (D.

11
Jones v. Walter Kidde Portable Equipment, Inc.green
mad · 1998 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
1 sentence

2015See Laaperi v. Sears, Roebuck & Co., 787 F.2d 726, 729 (1st Cir. 1986) (“the failure to warn of hazards associated with foreseeable uses of a product is itself negligence, and if that negligence proximately results in a plaintiff’s injuries, the plaintiff may recover”; applying Massachusetts law); Jones v. Walter Kidde Portable Equip., 16 F. Supp. 2d 123, 125 (D.

11
Commonwealth v. McGheegreen
mass · 2015 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
1 sentence

2015See id. at 645-646 ; Commonwealth v. Braun, 74 Mass. App. Ct. 904, 905-906 (2009).

11
Commonwealth v. Jacksongreen
mass · 2015 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
1 sentence

2015See *347 Commonwealth v. Jackson, 471 Mass. 262, 268-269 (2015) (finding procedural waiver despite fact that neither defendant nor defense counsel had been aware of closure).

11
Commonwealth v. Alebordgreen
massappct · 2011 · cited in 1 Massachusetts opinions naming this issue, 2014–2014
1 sentence

2014In so ruling, she relied on Commonwealth v. Alebord, 80 Mass. App. Ct. 432, 438-439 (2011) (Commonwealth must establish defendant knowingly waived right; silence not sufficient to establish knowing waiver). 7 Regardless of the lack of waiver, the judge concluded that the defendant’s Sixth Amendment rights were not violated because the closure was de minimis.

11
Commonwealth v. Bollinggreen
mass · 2012 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013Cf. Commonwealth v. Bolling, 462 Mass. 440, 452 (2012) (lack of instruction on element of case relieved Commonwealth of burden of proof and created substantial risk of miscarriage of justice).

11
Commonwealth v. Yeshulasgreen
massappct · 2001 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013Given that prior to the hearing on restitution, the juvenile’s counsel remarked that Blanchette’s home sustained more damage than Sergal’s house, and the lack of a requirement that the victim himself must document his loss, see Commonwealth v. Yeshulas, 51 Mass. App. Ct. 486, 492-493 (2001), we cannot say the judge abused his discretion in relying on an estimate for the similar type of damage.

11
Commonwealth v. Lapagegreen
mass · 2001 · cited in 1 Massachusetts opinions naming this issue, 2012–2012
1 sentence

2012When considering a failure to instruct on self-defense, a substantial risk of a miscarriage of justice occurs when the defendant was deprived of his primary argument of defense, Franchino, supra at 376 , citing Commonwealth v. Lapage, 435 Mass. 480, 487-488 (2001), or where the lack of the instruction relieved the Commonwealth of its full burden of proof.

11
Commonwealth v. Leonardigreen
massappct · 2010 · cited in 1 Massachusetts opinions naming this issue, 2010–2010
1 sentence

2010In such circumstances, however, there must be “sufficient other evidence in the record to demonstrate that the waiver was voluntary and intelligent.” Commonwealth v. Leonardi, 76 Mass. App. Ct. 271, 277 (2010).

11
Commonwealth v. Amiraultgreen
mass · 1997 · cited in 1 Massachusetts opinions naming this issue, 2001–2001
11
Commonwealth v. Piercegreen
mass · 1994 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
11
Commonwealth v. MacKenziegreen
mass · 1992 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
11
Griffin v. General Motors Corp.green
mass · 1980 · cited in 1 Massachusetts opinions naming this issue, 1994–1994
11
Commonwealth v. Owensgreen
mass · 1993 · cited in 1 Massachusetts opinions naming this issue, 1993–1993
11
Commonwealth v. Gregorygreen
mass · 1988 · cited in 1 Massachusetts opinions naming this issue, 1990–1990
11
Commonwealth v. Thomasgreen
mass · 1987 · cited in 1 Massachusetts opinions naming this issue, 1990–1990
11
Commonwealth v. Cavanaughgreen
mass · 1976 · cited in 1 Massachusetts opinions naming this issue, 1985–1985
11
Commonwealth v. Beneficial Finance Companygreen
mass · 1971 · cited in 1 Massachusetts opinions naming this issue, 1983–1983
11
DaGraca v. Feistgreen
mass · 1972 · cited in 1 Massachusetts opinions naming this issue, 1981–1981
11
Robinson v. Trustees of the New York, New Haven & Hartford Railroadgreen
mass · 1945 · cited in 1 Massachusetts opinions naming this issue, 1947–1947
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 (21)

CaseCitedYears
Commonwealth v. Roberts green
mass · 1996
1 sentence

2020Although the instructions do not track with precision the Criminal Model Jury Instructions for Use in the District Court (2009) (model instructions), they provided an "adequate and clear instruction[] on the applicable law," Commonwealth v. Roberts, 378 Mass. 116, 130 (1979), S.C., 423 Mass. 17 (1996), and neither the model instructions nor the supplemental instructions contain language about the piling of inferences.

12020–2020
Commonwealth v. Alphas green
mass · 1999
2 sentences

2017Id.

2017Id.

12017–2017
Commonwealth v. McGee green
mass · 2014
1 sentence

2017Id. 45 was low.

12017–2017
Commonwealth v. Ruddock green
mass · 1998
1 sentence

2015Where there has been an error in a trial resulting in a conviction of murder in the first degree, “a new trial is called for unless we are substantially confident that, if the error had not been made, the jury verdict would have been the same.” Figueroa, 468 Mass. at 229 , quoting Commonwealth v. Ruddock, 428 Mass. 288 , 292 *442 n.3 (1998).

12015–2015
Commonwealth v. Figueroa green
mass · 2014
1 sentence

2015Where there has been an error in a trial resulting in a conviction of murder in the first degree, “a new trial is called for unless we are substantially confident that, if the error had not been made, the jury verdict would have been the same.” Figueroa, 468 Mass. at 229 , quoting Commonwealth v. Ruddock, 428 Mass. 288 , 292 *442 n.3 (1998).

12015–2015
Commonwealth v. Johnson green
mass · 1992
1 sentence

2013The lack of instruction regarding the use of excessive force in defense of another left the jury with “no correct understanding” of mitigation, Commonwealth v. Johnson, supra, with the result that the jury were “given the option of considering that a murder ha[d] been committed.” Commonwealth v. Santos , 454 Mass, at 776.

12013–2013
Commonwealth v. Franchino green
massappct · 2004
1 sentence

2012When considering a failure to instruct on self-defense, a substantial risk of a miscarriage of justice occurs when the defendant was deprived of his primary argument of defense, Franchino, supra at 376 , citing Commonwealth v. Lapage, 435 Mass. 480, 487-488 (2001), or where the lack of the instruction relieved the Commonwealth of its full burden of proof.

12012–2012
Commonwealth v. Galvin green
massappct · 2002
1 sentence

2012Galvin, supra at 702 .

12012–2012
Commonwealth v. Howze green
massappct · 2003
1 sentence

2009In Commonwealth v. Howze, supra, a case involving facts remarkably similar to the case at hand, we addressed a similar lack of instruction.

12009–2009
Commonwealth v. Urban green
massappct · 2006
1 sentence

2008We agree with the Appeals Court’s disposition of these additional claims, see Commonwealth v. Urban, 67 Mass. App. Ct. 301 , 301 n.2 (2006), and we do not discuss them further.

12008–2008
Commonwealth v. Prater green
mass · 2000
1 sentence

2004Commonwealth v. Prater, supra, was decided after the trial of this case, and left open the question whether failure to instruct the jury that they may not consider evidence of the accomplice’s guilty plea as evidence against the defendant constitutes error.

12004–2004
State v. Pineau green
me · 1985
11992–1992
Hill v. State green
ala · 1979
11992–1992
State v. Willis green
minn · 1983
11992–1992
Commonwealth v. Satterfield green
mass · 1977
11990–1990
Commonwealth v. McDonald green
mass · 1928
11973–1973
Lonergan v. American Railway Express Co. green
mass · 1924
11947–1947
Commonwealth v. Dascalakis green
mass · 1923
11947–1947
Low Supply Co. v. Pappacostopoulous green
mass · 1933
11947–1947
Commonwealth v. McKnight green
mass · 1935
11947–1947
Belkus v. Murdoch green
mass · 1943
11947–1947

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 278, § 33E (10) MA § Mass. Gen. Laws ch. 265, § 1 (4) MA § Mass. Gen. Laws ch. 269, § 10 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 241 (1968–2026) CA 230 (1943–2026) OH 112 (1981–2025) PA 86 (1927–2026) WA 74 (1974–2025) IL 72 (1908–2026) NY 53 (1898–2023) FL 49 (1973–2026) NJ 44 (1941–2026) GA 43 (1964–2024) MS 41 (1965–2024) IN 40 (1975–2026) MO 40 (1942–2024) MI 37 (1914–2025) MA 34 (1947–2023) LA 25 (1967–2020) CT 25 (1943–2024) OK 24 (1932–2020) MN 24 (1975–2024) IA 21 (1975–2025) OR 21 (1988–2024) MD 20 (1951–2025) VT 18 (1977–2025) NC 18 (1973–2022) CO 18 (1991–2026) AZ 16 (1970–2024) KS 16 (1904–2024) NM 16 (1929–2024) WI 15 (1963–2025) AL 15 (1968–2025) UT 15 (1988–2026) TN 14 (1984–2021) WV 14 (1959–2026) DC 14 (1976–2023) ND 12 (1955–2021) KY 11 (1940–2026) HI 9 (1962–2023) WY 8 (1986–2019) RI 8 (1980–2010) NE 7 (1981–2026) NH 7 (1970–2023) MT 7 (1899–2025) VA 6 (1950–2010) NV 6 (1939–2021) ME 6 (1985–2025) SD 5 (2007–2020) SC 5 (1984–2002) AK 5 (1980–2015) ID 4 (1987–2023) AR 3 (1987–2018) DE 3 (1962–2025) GU 2 (2021–2022)

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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