defendant alleges waiver (Pennsylvania) · Go Syfert
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defendant alleges waiver in Pennsylvania

18 Pennsylvania opinions name it 2 courts 1904–2021 2 in the last five years

The cases below were cited by Pennsylvania 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 (8)

CaseFollowedCited
Commonwealth v. Sepulvedagreen
pa · 2012 · cited in 7 Pennsylvania opinions naming this issue, 2014–2020
2 sentences

2020When a defendant alleges that his waiver or confession was involuntary, the question is not whether the defendant would have confessed without interrogation, but whether the interrogation was so manipulative or coercive that it deprived the defendant of his ability to make a free and unconstrained decision to confess. [Commonwealth v. Sepulveda, 55 A.3d 1108, 1136-1137 (Pa. 2012 (quotation marks and quotations omitted).] Id. at 1268 (parallel citations omitted).

2019"When a defendant alleges that his waiver or confession was involuntary, the question 'is riot whether the defendant would have confessed without interrogation, but whether the interrogation was so manipulative or coercive that it deprived the defendant of his ability to make a free and unconstrained decision to confess .:" Commonwealth v. Sepulveda, 55 A.3d 1108, 1137 (Pa. 2012) (quoting Commonwealth v. Templin, 795 A.2d 959, 966 (Pa. 2002)).

67
Ness v. York Township Board of Commissionersgreen
pa · 2014 · cited in 4 Pennsylvania opinions naming this issue, 2015–2020
2 sentences

2020Commonwealth v. Mitchell, 105 A.3d 1257, 1268 (Pa. 2014) (some citations omitted).

2015“When a defendant alleges that his waiver or confession was involuntary, the question is not whether the defendant would have confessed without interrogation, but whether the interrogation was so manipulative or coercive that it deprived the defendant of his ability to make a free and unconstrained decision to confess.” Commonwealth v. Mitchell, 105 A.3d 1257, 1268 (Pa. 2014) (citations omitted).

44
Commonwealth v. Templingreen
pa · 2002 · cited in 3 Pennsylvania opinions naming this issue, 2012–2019
2 sentences

2019"When a defendant alleges that his waiver or confession was involuntary, the question 'is riot whether the defendant would have confessed without interrogation, but whether the interrogation was so manipulative or coercive that it deprived the defendant of his ability to make a free and unconstrained decision to confess .:" Commonwealth v. Sepulveda, 55 A.3d 1108, 1137 (Pa. 2012) (quoting Commonwealth v. Templin, 795 A.2d 959, 966 (Pa. 2002)).

2018"When a defendant alleges that his waiver or confession was involuntary, the question 'is not whether the defendant would have confessed without interrogation, but whether the interrogation was so manipulative or coercive that it deprived the defendant of his ability to make a free and unconstrained decision to confess!" Commonwealth v. Templin, 568 Pa. 306 , 3 - rubi-oeliteilue IVIULIUII 795 A.2d 959 , 966 (2002) (quoting Commonwealth v. Nester, 551 Pa. 157 , 709 A.2d 879, 882 (1998)).

23
Commonwealth v. DeCostagreen
pasuperct · 2018 · cited in 2 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021Commonwealth v. Tejada, 161 A.3d 313, 317 (Pa. Super. 2017). -5- J-S12015-21 Pennsylvania Rule of Criminal Procedure 6028 “dictates that a defendant shall be present at every stage of a trial[,] including the impaneling of the jury and the return of the verdict, except as otherwise provided by the rule.” Commonwealth v. Decosta, 197 A.3d 813, 816 (Pa. Super. 2018).

2021Commonwealth v. Tejada, 161 A.3d 313, 317 (Pa. Super. 2017). -5- J-S12015-21 Pennsylvania Rule of Criminal Procedure 6028 “dictates that a defendant shall be present at every stage of a trial[,] including the impaneling of the jury and the return of the verdict, except as otherwise provided by the rule.” Commonwealth v. Decosta, 197 A.3d 813, 816 (Pa. Super. 2018).

22
Commonwealth v. Tejadagreen
pasuperct · 2017 · cited in 2 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021Commonwealth v. Tejada, 161 A.3d 313, 317 (Pa. Super. 2017). -5- J-S12015-21 Pennsylvania Rule of Criminal Procedure 6028 “dictates that a defendant shall be present at every stage of a trial[,] including the impaneling of the jury and the return of the verdict, except as otherwise provided by the rule.” Commonwealth v. Decosta, 197 A.3d 813, 816 (Pa. Super. 2018).

2021Commonwealth v. Tejada, 161 A.3d 313, 317 (Pa. Super. 2017). -5- J-S12015-21 Pennsylvania Rule of Criminal Procedure 6028 “dictates that a defendant shall be present at every stage of a trial[,] including the impaneling of the jury and the return of the verdict, except as otherwise provided by the rule.” Commonwealth v. Decosta, 197 A.3d 813, 816 (Pa. Super. 2018).

22
Commonwealth v. Nestergreen
pa · 1998 · cited in 2 Pennsylvania opinions naming this issue, 2012–2018
2 sentences

2018"When a defendant alleges that his waiver or confession was involuntary, the question 'is not whether the defendant would have confessed without interrogation, but whether the interrogation was so manipulative or coercive that it deprived the defendant of his ability to make a free and unconstrained decision to confess!" Commonwealth v. Templin, 568 Pa. 306 , 3 - rubi-oeliteilue IVIULIUII 795 A.2d 959 , 966 (2002) (quoting Commonwealth v. Nester, 551 Pa. 157 , 709 A.2d 879, 882 (1998)).

2018"When a defendant alleges that his waiver or confession was involuntary, the question 'is not whether the defendant would have confessed without interrogation, but whether the interrogation was so manipulative or coercive that it deprived the defendant of his ability to make a free and unconstrained decision to confess!" Commonwealth v. Templin, 568 Pa. 306 , 3 - rubi-oeliteilue IVIULIUII 795 A.2d 959 , 966 (2002) (quoting Commonwealth v. Nester, 551 Pa. 157 , 709 A.2d 879, 882 (1998)).

22
Commonwealth v. Wholavergreen
pa · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Moreover, "'[i]n reviewing a ruling on a suppression motion, the standard of review is whether the factual findings and legal conclusions drawn therefrom are supported by the evidence.!" Commonwealth v, Who/aver, 989 A.2d 883, 896 (Pa. 2010) (quoting Commonwealth v. Bronshtein, 691 A.2d 907, 913 (Pa. 1997)).

11
Commonwealth v. Bronshteingreen
pa · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Moreover, "'[i]n reviewing a ruling on a suppression motion, the standard of review is whether the factual findings and legal conclusions drawn therefrom are supported by the evidence.!" Commonwealth v, Who/aver, 989 A.2d 883, 896 (Pa. 2010) (quoting Commonwealth v. Bronshtein, 691 A.2d 907, 913 (Pa. 1997)).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Crawford v. Stewart neutral
pa · 1861
2 sentences

1927The cause is to be tried without relation to an equitable plaintiff, unless an issue is raised between such plaintiff and the defendant; as when a defense is set up which, while good against the legal plaintiff, cannot be made against the equitable plaintiff, or the defendant alleges a defense or a counterclaim against the latter which would not avail against the former: Berks County v. Levan, 86 Pa. 360 ; Crawford v. Stewart, 38 Pa. 34 .” As the defendant averred no defense to the right of the legal plaintiff to recover the sum of $1,110.22, the judgment for that amount was properly entered a

1904The cause is to be tried without relation to an equitable plaintiff, unless an issue is raised between such plaintiff and the defendant; as when a defense is set up which, while good against the legal plaintiff, cannot be made against the equitable plaintiff, or the defendant alleges a defense or a counterclaim against the latter which would not avail against the former: Berks County v. Levan, 86 Pa. 360 ; Crawford v. Stewart, 38 Pa. 34 .

21904–1927
Berks County ex rel. School District v. Levan green
pa · 1878
2 sentences

1927The cause is to be tried without relation to an equitable plaintiff, unless an issue is raised between such plaintiff and the defendant; as when a defense is set up which, while good against the legal plaintiff, cannot be made against the equitable plaintiff, or the defendant alleges a defense or a counterclaim against the latter which would not avail against the former: Berks County v. Levan, 86 Pa. 360 ; Crawford v. Stewart, 38 Pa. 34 .” As the defendant averred no defense to the right of the legal plaintiff to recover the sum of $1,110.22, the judgment for that amount was properly entered a

1904The cause is to be tried without relation to an equitable plaintiff, unless an issue is raised between such plaintiff and the defendant; as when a defense is set up which, while good against the legal plaintiff, cannot be made against the equitable plaintiff, or the defendant alleges a defense or a counterclaim against the latter which would not avail against the former: Berks County v. Levan, 86 Pa. 360 ; Crawford v. Stewart, 38 Pa. 34 .

21904–1927
Commonwealth v. Busanet green
pa · 2012
1 sentence

2014Sepulveda, 618 Pa. at 309-10 , 55 A.3d at 1136-37 (quotation marks and quotations omitted).

12014–2014
Gandy v. Weckerly green
pa · 1908
1 sentence

1914Whether the appellant will be able to sustain his defense by the proper measure of proof is not a question now before us: Gandy v. Weckerly, 220 Pa. 285 (293).

11914–1914

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9543 (5) PA § 18 Pa. Cons. Stat. § 907 (4) PA § 42 Pa. Cons. Stat. § 9544 (4) PA § 18 Pa. Cons. Stat. § 2502 (3) PA § 18 Pa. Cons. Stat. § 2702 (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

CT 21 (1953–2025) PA 18 (1904–2021) IL 8 (1964–2026) MA 8 (1975–2014) WA 8 (1997–2025) NE 7 (1907–2004) NC 6 (1907–2025) TN 6 (2008–2019) TX 6 (2002–2020) NM 6 (1981–2019) WI 5 (1981–2020) AL 5 (1976–2008) ID 5 (2010–2014) NY 5 (1898–2024) MO 5 (1957–2017) KS 4 (2004–2022) NJ 4 (2020–2025) FL 4 (2001–2006) MN 4 (2004–2013) HI 4 (2003–2025) RI 4 (1983–2019) ME 3 (2013–2021) MI 3 (1980–2018) OK 3 (1974–1976) MS 3 (2006–2008) IA 3 (1995–2014) NH 2 (2002–2005) LA 2 (1985–1999)

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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