rigorous standard (Massachusetts) · Go Syfert
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rigorous standard in Massachusetts

32 Massachusetts opinions name it 4 courts 1973–2026 7 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 (28)

CaseFollowedCited
Commonwealth v. Berriosgreen
mass · 2006 · cited in 5 Massachusetts opinions naming this issue, 2007–2025
2 sentences

2025"Although the disposition of such a motion is within the discretion of the judge, a rigorous standard must be applied and a judge may only allow such a motion 'if it appears that justice may not have been done.'" Commonwealth v. Berrios, 447 Mass. 701, 708 (2006), quoting Commonwealth v. DeMarco, 387 Mass. 481, 482 (1982).

2013It would be manifestly unjust on this view not to permit him to withdraw his plea and to receive a new trial.* **** 5 See Commonwealth v. Berrios, 447 Mass. 701, 708 (2006), cert, denied, 550 U.S. 907 (2007), quoting Commonwealth v. DeMarco, 387 Mass. 481, 482 (1982) (“Although the disposition of [a motion to withdraw a guilty plea] is within the discretion of the judge, a rigorous standard must be applied and a judge may only allow such a motion ‘if it appears that justice may not have been done’ ”); Commonwealth v. Tennison, 440 Mass. 553, 566 (2003), quoting Commonwealth v. Russin, 420 Mass

55
Commonwealth v. DeMarcogreen
mass · 1982 · cited in 4 Massachusetts opinions naming this issue, 2006–2025
2 sentences

2025"Although the disposition of such a motion is within the discretion of the judge, a rigorous standard must be applied and a judge may only allow such a motion 'if it appears that justice may not have been done.'" Commonwealth v. Berrios, 447 Mass. 701, 708 (2006), quoting Commonwealth v. DeMarco, 387 Mass. 481, 482 (1982).

2013It would be manifestly unjust on this view not to permit him to withdraw his plea and to receive a new trial.* **** 5 See Commonwealth v. Berrios, 447 Mass. 701, 708 (2006), cert, denied, 550 U.S. 907 (2007), quoting Commonwealth v. DeMarco, 387 Mass. 481, 482 (1982) (“Although the disposition of [a motion to withdraw a guilty plea] is within the discretion of the judge, a rigorous standard must be applied and a judge may only allow such a motion ‘if it appears that justice may not have been done’ ”); Commonwealth v. Tennison, 440 Mass. 553, 566 (2003), quoting Commonwealth v. Russin, 420 Mass

44
Commonwealth v. Langgreen
mass · 2015 · cited in 4 Massachusetts opinions naming this issue, 2017–2020
2 sentences

2017Where the defendant’s ineffective assistance claim is based on a tactical or strategic decision, we apply the more rigorous standard that, to be ineffective, the attorney’s decision must have been ‘“manifestly unreasonable.” Commonwealth v. Lang, 473 Mass. 1, 14 (2015). i. Failure to introduce exculpatory CSLI evidence.

2017Where the defendant's ineffective assistance claim is based on a tactical or strategic decision, we apply the more rigorous standard that, to be ineffective, the attorney's decision must have been "manifestly unreasonable." Commonwealth v. Lang, 473 Mass. 1, 14 (2015). i. Failure to introduce exculpatory CSLI evidence.

44
Commonwealth v. Hollandgreen
mass · 2017 · cited in 2 Massachusetts opinions naming this issue, 2025–2025
2 sentences

2025Applying this standard, "we evaluate the [strategic or tactical] decision at the time it was made, and make every effort . . . to eliminate the distorting effects of hindsight." Id., quoting Commonwealth v. Holland, 476 Mass. 801, 812 (2017).

2025"Only strategy and tactics which lawyers of ordinary training and skill in criminal law would not consider competent are manifestly unreasonable." Id., quoting Holland, 476 Mass. at 812 .

12
Commonwealth v. Ayalagreen
mass · 2018 · cited in 1 Massachusetts opinions naming this issue, 2026–2026
1 sentence

2026"The decision to call, or not to call, an expert witness fits squarely within the realm of strategic or tactical decisions." Henderson, 486 Mass. at 306, quoting Commonwealth v. Ayala, 481 Mass. 46, 63 (2018).

11
Brady v. United Statesgreen
scotus · 1970 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025Brady v. United States, 397 U.S. 742, 749 (1970).

11
Commonwealth v. Craytongreen
mass · 2014 · cited in 1 Massachusetts opinions naming this issue, 2022–2022
1 sentence

2022See Commonwealth v. Crayton, 470 Mass. 228, 234 (2014). [Note 7] The defendant makes several additional claims surrounding the failure to follow certain recommended procedures in the identification process.

11
Commonwealth v. Byfieldgreen
mass · 1992 · cited in 1 Massachusetts opinions naming this issue, 2021–2021
1 sentence

2021See Commonwealth v. Byfield, 413 Mass. 426, 431 (1992) (informant's veracity established where prior information led to arrest and conviction).

11
Commonwealth v. Gonsalvesgreen
mass · 1999 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
1 sentence

2020The court notes that the Supreme Judicial Court has observed that "routine traffic stops may also pose unique hardships on minorities who, it has been argued, are often the subject of stops on pretext." Commonwealth v. Gonsalves, 429 Mass. 658, 663 (1999). -11- permissible scope, proportionality is the touchstone.

11
Commonwealth v. Kolenovicgreen
mass · 2015 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
1 sentence

2020See Commonwealth v. Lang, 473 Mass. 1, 14 (2015); Commonwealth v. Kolenovic, 471 Mass. 664, 674-675 (2015), S.C., 478 Mass. 189 (2017). i. Motion to suppress identification.

11
Williams v. Rhodesgreen
scotus · 1968 · cited in 1 Massachusetts opinions naming this issue, 2018–2018
2 sentences

2018This is because, as the Court first explained in Buckley , contribution limits encroach to a lesser extent on First Amendment interests than independent expenditure limits: whereas independent expenditures are themselves a form of political expression, lying "at the core ... of the First Amendment freedoms," Buckley , 424 U.S. at 39 , 96 S.Ct. 612 , quoting Williams v. Rhodes , 393 U.S. 23 , 32, 89 S.Ct. 5 , 21 L.Ed.2d 24 (1968), a contribution is merely "a general expression of support for the candidate and his views, [which] does not communicate the underlying basis for the support." Buckley

2018This is because, as the Court first explained in Buckley , contribution limits encroach to a lesser extent on First Amendment interests than independent expenditure limits: whereas independent expenditures are themselves a form of political expression, lying "at the core ... of the First Amendment freedoms," Buckley , 424 U.S. at 39 , 96 S.Ct. 612 , quoting Williams v. Rhodes , 393 U.S. 23 , 32, 89 S.Ct. 5 , 21 L.Ed.2d 24 (1968), a contribution is merely "a general expression of support for the candidate and his views, [which] does not communicate the underlying basis for the support." Buckley

11
Commonwealth v. Escaleragreen
mass · 2012 · cited in 1 Massachusetts opinions naming this issue, 2016–2016
2 sentences

2016As we recently observed, “[n]o bright-line rule can establish whether there is a nexus between suspected drug dealing and a defendant’s home.” Commonwealth v. Escalera, 462 Mass. 636, 643 (2012).

2016As we recently observed, "[n]o bright-line rule can establish whether there is a nexus between suspected drug dealing and a defendant's home." Commonwealth v. Escalera, 462 Mass. 636, 643 (2012).

11
Hanlon v. Rollinsgreen
mass · 1934 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013This claim rests upon a distinction that the defendant perceives in the sex offender registration act between a sex offender and a “sex offender required to register”; he maintains that he was at all relevant times only the former and not the latter. 6 “[A] statute must be interpreted according to the intent of the Legislature ascertained from all its words . . . considered in connection with the cause of its enactment, the mischief or imperfection to be remedied and the main object to be accomplished.” Commonwealth v. De’Amicis, 450 Mass. 271, 276 (2007), quoting Hanlon v. Rollins, 286 Mass.

11
Commonwealth v. Russingreen
mass · 1995 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013It would be manifestly unjust on this view not to permit him to withdraw his plea and to receive a new trial.* **** 5 See Commonwealth v. Berrios, 447 Mass. 701, 708 (2006), cert, denied, 550 U.S. 907 (2007), quoting Commonwealth v. DeMarco, 387 Mass. 481, 482 (1982) (“Although the disposition of [a motion to withdraw a guilty plea] is within the discretion of the judge, a rigorous standard must be applied and a judge may only allow such a motion ‘if it appears that justice may not have been done’ ”); Commonwealth v. Tennison, 440 Mass. 553, 566 (2003), quoting Commonwealth v. Russin, 420 Mass

11
Commonwealth v. De'Amicisgreen
mass · 2007 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013This claim rests upon a distinction that the defendant perceives in the sex offender registration act between a sex offender and a “sex offender required to register”; he maintains that he was at all relevant times only the former and not the latter. 6 “[A] statute must be interpreted according to the intent of the Legislature ascertained from all its words . . . considered in connection with the cause of its enactment, the mischief or imperfection to be remedied and the main object to be accomplished.” Commonwealth v. De’Amicis, 450 Mass. 271, 276 (2007), quoting Hanlon v. Rollins, 286 Mass.

11
Commonwealth v. Tennisongreen
mass · 2003 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013It would be manifestly unjust on this view not to permit him to withdraw his plea and to receive a new trial.* **** 5 See Commonwealth v. Berrios, 447 Mass. 701, 708 (2006), cert, denied, 550 U.S. 907 (2007), quoting Commonwealth v. DeMarco, 387 Mass. 481, 482 (1982) (“Although the disposition of [a motion to withdraw a guilty plea] is within the discretion of the judge, a rigorous standard must be applied and a judge may only allow such a motion ‘if it appears that justice may not have been done’ ”); Commonwealth v. Tennison, 440 Mass. 553, 566 (2003), quoting Commonwealth v. Russin, 420 Mass

11
Commonwealth v. Latimoregreen
mass · 1979 · cited in 1 Massachusetts opinions naming this issue, 2011–2011
1 sentence

2011This standard requires more exacting review than the less rigorous standard of Commonwealth v. Latimore, 378 Mass. 671, 677-678 (1979).

11
Iannacchino v. Ford Motor Co.green
mass · 2008 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
1 sentence

2008See Iannacchino v. Ford Motor Co., 451 Mass. 623 (2008).

11
Commonwealth v. Milleygreen
massappct · 2006 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
1 sentence

2008In reviewing the disposition of a motion for a new trial, we must “determine whether there has been a significant error of law or other abuse of discretion.” Commonwealth v. Milley, 67 Mass. App. Ct. 685, 687 (2006), quoting from Commonwealth v. Grace, 397 Mass. 303, 307 (1986).

11
Commonwealth v. Gracegreen
mass · 1986 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
1 sentence

2008In reviewing the disposition of a motion for a new trial, we must “determine whether there has been a significant error of law or other abuse of discretion.” Commonwealth v. Milley, 67 Mass. App. Ct. 685, 687 (2006), quoting from Commonwealth v. Grace, 397 Mass. 303, 307 (1986).

11
Commonwealth v. Correagreen
massappct · 1997 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
1 sentence

2007In the context of a guilty plea, justice is not done when a defendant’s plea of guilt is not intelligent and voluntary, 5 see Boykin v. Alabama, 395 U.S. 238, 242 (1969); Commonwealth v. Correa, 43 Mass. App. Ct. 714, 111 (1997); Commonwealth v. Brannon B., 66 Mass. App. Ct. 97, 98 (2006), or is made without the advice of competent counsel.

11
Commonwealth v. Brannon B.green
massappct · 2006 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
11
Boykin v. Alabamagreen
scotus · 1969 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
11
Commonwealth v. Lyonsgreen
mass · 1990 · cited in 1 Massachusetts opinions naming this issue, 2003–2003
11
United States v. Armstronggreen
scotus · 1996 · cited in 1 Massachusetts opinions naming this issue, 2001–2001
11
United States v. Virginiagreen
scotus · 1996 · cited in 1 Massachusetts opinions naming this issue, 1999–1999
11
Commonwealth v. Perrotgreen
mass · 1990 · cited in 1 Massachusetts opinions naming this issue, 1997–1997
11
Foell Packing Co. v. Harrisgreen
pasuperct · 1937 · cited in 1 Massachusetts opinions naming this issue, 1973–1973
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 (16)

CaseCitedYears
Federal Election Commission v. Beaumont green
scotus · 2003
2 sentences

2018As the Court stated, independent expenditure limits are subject to strict scrutiny, whereas contribution limits are reviewed under a less rigorous standard, and will be upheld as long as they are " 'closely drawn' to match a 'sufficiently important interest.' " Beaumont , 539 U.S. at 162 , 123 S.Ct. 2200 , quoting Nixon v. Shrink Missouri Gov't PAC , 528 U.S. 377 , 387-388, 120 S.Ct. 897 , 145 L.Ed.2d 886 (2000).

2018As the Court stated, independent expenditure limits are subject to strict scrutiny, whereas contribution limits are reviewed under a less rigorous standard, and will be upheld as long as they are " 'closely drawn' to match a 'sufficiently important interest.' " Beaumont , 539 U.S. at 162 , 123 S.Ct. 2200 , quoting Nixon v. Shrink Missouri Gov't PAC , 528 U.S. 377 , 387-388, 120 S.Ct. 897 , 145 L.Ed.2d 886 (2000).

12018–2018
cluster 1741 green
·
2 sentences

2018But this time, the **441 plaintiffs seek to avail themselves of a more rigorous standard of review, contending that -- although under the First Amendment, § 8 need only be "closely drawn" to advance a "sufficiently important interest," Beaumont , 539 U.S. at 162 , 123 S.Ct. 2200 -- under equal protection principles, it is subject to strict scrutiny, and therefore must be "narrowly tailored" to serve a "compelling interest." See Citizens United , 558 U.S. at 340 , 130 S.Ct. 876 .

2018But this time, the **441 plaintiffs seek to avail themselves of a more rigorous standard of review, contending that -- although under the First Amendment, § 8 need only be "closely drawn" to advance a "sufficiently important interest," Beaumont , 539 U.S. at 162 , 123 S.Ct. 2200 -- under equal protection principles, it is subject to strict scrutiny, and therefore must be "narrowly tailored" to serve a "compelling interest." See Citizens United , 558 U.S. at 340 , 130 S.Ct. 876 .

12018–2018
Commonwealth v. Gomes green
mass · 2009
1 sentence

2018Ipso facto, there is no per se rule requiring that police see an object exchanged in cases where, as here, the less rigorous standard of reasonable suspicion applies. 10 In Commonwealth v. Gomes , the court held that the police officer had reasonable suspicion to stop the defendant in a high crime area at around 4 a.m. , where the defendant was known to previously have been arrested on drug charges and was observed "displaying items in his hand[, which the officers could not see,] and then appearing to swallow those items as the [police] approached." 453 Mass. at 511, 903 N.E.2d 567 .

12018–2018
Commonwealth v. Gordon green
massappct · 2012
1 sentence

2018"The policy favoring the finality of just convictions imposes a rigorous standard upon the discretionary allowance of motions under rule 30(b)," Commonwealth v. Almonte , 84 Mass. App. Ct. 735 , 738 (2014) (quotation omitted), which should happen only in "exceptional situations." Commonwealth v. Gordon , 82 Mass. App. Ct. 389 , 394 (2012).

12018–2018
Commonwealth v. Almonte green
massappct · 2014
1 sentence

2018"The policy favoring the finality of just convictions imposes a rigorous standard upon the discretionary allowance of motions under rule 30(b)," Commonwealth v. Almonte , 84 Mass. App. Ct. 735 , 738 (2014) (quotation omitted), which should happen only in "exceptional situations." Commonwealth v. Gordon , 82 Mass. App. Ct. 389 , 394 (2012).

12018–2018
Nixon v. Shrink Missouri Government PAC green
scotus · 2000
2 sentences

2018As the Court stated, independent expenditure limits are subject to strict scrutiny, whereas contribution limits are reviewed under a less rigorous standard, and will be upheld as long as they are " 'closely drawn' to match a 'sufficiently important interest.' " Beaumont , 539 U.S. at 162 , 123 S.Ct. 2200 , quoting Nixon v. Shrink Missouri Gov't PAC , 528 U.S. 377 , 387-388, 120 S.Ct. 897 , 145 L.Ed.2d 886 (2000).

2018As the Court stated, independent expenditure limits are subject to strict scrutiny, whereas contribution limits are reviewed under a less rigorous standard, and will be upheld as long as they are " 'closely drawn' to match a 'sufficiently important interest.' " Beaumont , 539 U.S. at 162 , 123 S.Ct. 2200 , quoting Nixon v. Shrink Missouri Gov't PAC , 528 U.S. 377 , 387-388, 120 S.Ct. 897 , 145 L.Ed.2d 886 (2000).

12018–2018
Buckley v. Valeo green
scotus · 1976
2 sentences

2018This is because, as the Court first explained in Buckley , contribution limits encroach to a lesser extent on First Amendment interests than independent expenditure limits: whereas independent expenditures are themselves a form of political expression, lying "at the core ... of the First Amendment freedoms," Buckley , 424 U.S. at 39 , 96 S.Ct. 612 , quoting Williams v. Rhodes , 393 U.S. 23 , 32, 89 S.Ct. 5 , 21 L.Ed.2d 24 (1968), a contribution is merely "a general expression of support for the candidate and his views, [which] does not communicate the underlying basis for the support." Buckley

2018This is because, as the Court first explained in Buckley , contribution limits encroach to a lesser extent on First Amendment interests than independent expenditure limits: whereas independent expenditures are themselves a form of political expression, lying "at the core ... of the First Amendment freedoms," Buckley , 424 U.S. at 39 , 96 S.Ct. 612 , quoting Williams v. Rhodes , 393 U.S. 23 , 32, 89 S.Ct. 5 , 21 L.Ed.2d 24 (1968), a contribution is merely "a general expression of support for the candidate and his views, [which] does not communicate the underlying basis for the support." Buckley

12018–2018
Commonwealth v. Moses green
mass · 1990
2 sentences

2018In Commonwealth v. Moses , the court held that the police officer "had reason to suspect that a drug transaction was taking place" where he saw four individuals who were "standing near an automobile parked next to the sidewalk with its motor running [and] appeared to be interacting in some way with three ... men who sat in the automobile[, and then, o]n making eye contact with [the officer,] all four [men on the sidewalk] quickly dispersed in two different directions[, and] [o]ne of the occupants of the automobile, on making eye contact with [the officer], immediately ducked under the dashboar

2018In Commonwealth v. Moses , the court held that the police officer "had reason to suspect that a drug transaction was taking place" where he saw four individuals who were "standing near an automobile parked next to the sidewalk with its motor running [and] appeared to be interacting in some way with three ... men who sat in the automobile[, and then, o]n making eye contact with [the officer,] all four [men on the sidewalk] quickly dispersed in two different directions[, and] [o]ne of the occupants of the automobile, on making eye contact with [the officer], immediately ducked under the dashboar

12018–2018
Commonwealth v. Dagraca green
mass · 2006
1 sentence

2011Commonwealth v. Dagraca, 447 Mass. 546, 555 (2006).

12011–2011
Helvering v. Gregory green
ca2 · 1934
12002–2002
Commonwealth v. O'CONNOR green
mass · 1989
11997–1997
Commonwealth v. Ferreira green
mass · 1980
11981–1981
New York Times Co. v. Sullivan green
scotus · 1964
11981–1981
Commonwealth v. Hanger green
mass · 1979
11981–1981
Silversmith v. Sydeman green
mass · 1940
11975–1975
Samia v. Central Oil Co. of Worcester green
mass · 1959
11975–1975

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 278, § 33E (6) MA § Mass. Gen. Laws ch. 94C, § 32E (3)

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 182 (1915–2026) IN 129 (1989–2025) CA 99 (1923–2026) OH 96 (1991–2025) LA 80 (1911–2022) NY 67 (1899–2026) IL 64 (1941–2025) OR 62 (1928–2026) FL 46 (1974–2025) NJ 39 (1976–2025) AL 39 (1917–2026) ID 34 (1972–2023) MA 32 (1973–2026) WA 30 (1944–2023) NC 28 (1913–2021) PA 28 (1925–2026) MD 23 (1925–2026) KS 22 (1879–2024) NV 22 (1996–2024) DC 21 (1952–2023) AR 20 (1893–2024) GA 20 (1983–2025) MI 19 (1919–2025) CT 19 (1976–2025) ND 18 (1982–2002) WI 18 (1923–2025) RI 17 (1983–2015) TN 17 (1931–2025) NM 16 (1978–2021) MN 15 (1972–2018) VT 14 (1980–2026) UT 14 (1933–2016) WY 14 (1893–2025) MO 13 (1958–2025) ME 13 (1972–2020) KY 13 (1946–2025) WV 11 (1909–2022) CO 11 (1995–2022) IA 11 (1915–2026) AZ 10 (1981–2026) VA 10 (1906–2020) AK 6 (1972–2011) DE 6 (1989–2026) NH 5 (1990–2018) MT 4 (1900–2016) OK 4 (2007–2023) MS 3 (1998–2018) SD 3 (2003–2013) HI 3 (1981–2009) NE 2 (1897–2004) SC 2 (1989–2018)

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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