range exception (Massachusetts) · Go Syfert
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range exception in Massachusetts

14 Massachusetts opinions name it 3 courts 1927–2026 3 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 (14)

CaseFollowedCited
Morrison v. Californiagreen
scotus · 1934 · cited in 2 Massachusetts opinions naming this issue, 1980–2012
2 sentences

2012Finally, the United States Supreme Court has explicitly recognized that States may place the burden of proving an affirmative defense on a defendant, see Martin v. Ohio, 480 U.S. 228, 235-236 (1987), and Patterson v. New York, 432 U.S. 197, 210 (1977); particularly where there exists a “disparity in convenience of proof and opportunity for knowledge, as, for instance, where a general prohibition is applicable to every one who is unable to bring himself within the range of an exception.” Morrison v. California, 291 U.S. 82, 91 (1934).

1980“Such a shift may be proper if there is a ‘manifest disparity in convenience of proof and opportunity for knowledge as, for instance, where a general prohibition is applicable to everyone who is unable to bring himself within the range of an exception’.” Commonwealth v. Jones, supra at 408 , quoting from Morrison v. California, 291 U.S. 82, 91 (1934).

22
Commonwealth v. Biancogreen
mass · 1983 · cited in 2 Massachusetts opinions naming this issue, 1988–2002
2 sentences

2002Cf. Commonwealth v. Bianco, 390 Mass. 254, 259 (1983) (a judge may consider a broad range of factors in making sentence determinations); Commonwealth v. Knight, 392 Mass. 192, 196-197 (1984).

1988Commonwealth v. Bianco, 390 Mass. 254, 259 (1983).

22
Ardizoni v. Raymondgreen
massappct · 1996 · cited in 1 Massachusetts opinions naming this issue, 2026–2026
1 sentence

2026See Ardizoni v. Raymond, 40 Mass. App. Ct. 734, 738 (1996).

11
Commonwealth v. Sawyergreen
mass · 1983 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024"In exercising our powers under . . . § 33E, we do not act as a second jury." Commonwealth v. Sawyer, 389 Mass. 686, 704 (1983). 30 In her request for relief under § 33E, the defendant raises many issues that were presented at trial and argued to the jury.

11
Commonwealth v. Berrygreen
mass · 2014 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
1 sentence

2023"Our power under [§ 33E] directs us to consider a defendant's entire case, taking into account a broad range of factors, when determining whether a conviction of murder in the first degree was a miscarriage of justice that warrants a reduction in the degree of guilt." Concepcion, 487 Mass. at 94, quoting Commonwealth v. Berry, 466 Mass. 763, 770 (2014).

11
Commonwealth v. Collerangreen
mass · 2008 · cited in 1 Massachusetts opinions naming this issue, 2014–2014
1 sentence

2014See Commonwealth v. Colleran, 452 Mass. 417, 430-431 (2008).

11
United States v. Robert W. Unsergreen
ca10 · 1999 · cited in 1 Massachusetts opinions naming this issue, 2012–2012
1 sentence

2012See Patterson v. New York, supra; United States v. Deleveaux, supra; United States v. Unser, 165 F.3d 755, 765 (10th Cir.), cert. denied, 528 U.S. 809 (1999).

11
Martin v. Ohiogreen
scotus · 1987 · cited in 1 Massachusetts opinions naming this issue, 2012–2012
1 sentence

2012Finally, the United States Supreme Court has explicitly recognized that States may place the burden of proving an affirmative defense on a defendant, see Martin v. Ohio, 480 U.S. 228, 235-236 (1987), and Patterson v. New York, 432 U.S. 197, 210 (1977); particularly where there exists a “disparity in convenience of proof and opportunity for knowledge, as, for instance, where a general prohibition is applicable to every one who is unable to bring himself within the range of an exception.” Morrison v. California, 291 U.S. 82, 91 (1934).

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

2011Linthicum v. Archambault, 379 Mass. 381, 388-89 (1979).

11
Commonwealth v. Knightgreen
mass · 1984 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
1 sentence

2002Cf. Commonwealth v. Bianco, 390 Mass. 254, 259 (1983) (a judge may consider a broad range of factors in making sentence determinations); Commonwealth v. Knight, 392 Mass. 192, 196-197 (1984).

11
Carney v. City of Springfieldgreen
mass · 1988 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
2 sentences

1996This is consistent with the statement in Carney v. Springfield, 403 Mass. 604, 610 (1988): “In Massachusetts, art. 12 of the Declaration of Rights requires transactional immunity to supplant the privilege against self-incrimination, even in the context of public employment.” See id. at 611 , stating that Baker v. Lawrence, 379 Mass. 322 (1979), Silverio v. Municipal Court of the City of Boston, 355 Mass. 623 , cert, denied, 396 U.S. 878 (1969), and Patch v. Mayor of Revere, 397 Mass. 454 (1986), are all inapposite as no claim was made in those cases under art. 12.

1996This is consistent with the statement in Carney v. Springfield, 403 Mass. 604, 610 (1988): “In Massachusetts, art. 12 of the Declaration of Rights requires transactional immunity to supplant the privilege against self-incrimination, even in the context of public employment.” See id. at 611 , stating that Baker v. Lawrence, 379 Mass. 322 (1979), Silverio v. Municipal Court of the City of Boston, 355 Mass. 623 , cert, denied, 396 U.S. 878 (1969), and Patch v. Mayor of Revere, 397 Mass. 454 (1986), are all inapposite as no claim was made in those cases under art. 12.

11
Commonwealth v. Sparegreen
mass · 1967 · cited in 1 Massachusetts opinions naming this issue, 1985–1985
1 sentence

1985During cross-examina-tian the prosecutor asked questions clearly indicating that the defendant had been in jail on occasions prior to his arrest for these crimes. 7 Cross-examination is not limited to a narrow range of inquiry, Hathaway v. Crocker, 7 Met. 262 , 266 (1843), but the introduction of prejudicial material is not permitted, see Commonwealth v. Spare, 353 Mass. 263, 267 (1967).

11
Commonwealth v. Corcorangreen
mass · 1925 · cited in 1 Massachusetts opinions naming this issue, 1966–1966
1 sentence

1966See Commonwealth v. Corcoran, 252 Mass. 465, 486 . 8.

11
Wright v. Lyonsgreen
mass · 1916 · cited in 1 Massachusetts opinions naming this issue, 1927–1927
1 sentence

1927See Wright v. Lyons, 224 Mass. 167, 169 .

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 (10)

CaseCitedYears
United States v. Deleveaux green
ca11 · 2000
1 sentence

2012See Patterson v. New York, supra; United States v. Deleveaux, supra; United States v. Unser, 165 F.3d 755, 765 (10th Cir.), cert. denied, 528 U.S. 809 (1999).

12012–2012
Albertson's, Inc. v. United Food & Commercial Workers International Union green
scotus · 1999
1 sentence

2012See Patterson v. New York, supra; United States v. Deleveaux, supra; United States v. Unser, 165 F.3d 755, 765 (10th Cir.), cert. denied, 528 U.S. 809 (1999).

12012–2012
Patterson v. New York green
scotus · 1977
1 sentence

2012Finally, the United States Supreme Court has explicitly recognized that States may place the burden of proving an affirmative defense on a defendant, see Martin v. Ohio, 480 U.S. 228, 235-236 (1987), and Patterson v. New York, 432 U.S. 197, 210 (1977); particularly where there exists a “disparity in convenience of proof and opportunity for knowledge, as, for instance, where a general prohibition is applicable to every one who is unable to bring himself within the range of an exception.” Morrison v. California, 291 U.S. 82, 91 (1934).

12012–2012
Baker v. City of Lawrence green
mass · 1979
1 sentence

1996This is consistent with the statement in Carney v. Springfield, 403 Mass. 604, 610 (1988): “In Massachusetts, art. 12 of the Declaration of Rights requires transactional immunity to supplant the privilege against self-incrimination, even in the context of public employment.” See id. at 611 , stating that Baker v. Lawrence, 379 Mass. 322 (1979), Silverio v. Municipal Court of the City of Boston, 355 Mass. 623 , cert, denied, 396 U.S. 878 (1969), and Patch v. Mayor of Revere, 397 Mass. 454 (1986), are all inapposite as no claim was made in those cases under art. 12.

11996–1996
Baglioni v. Chief of Police green
mass · 1995
1 sentence

1996“Unless the district attorney had authority to grant the full range of immunity to which the plaintiff officers were entitled, the government may not oblige them to make statements at the risk that, if they do not do so, they might lose their jobs.” Id. at 232 .

11996–1996
Silverio v. Municipal Court of the City of Boston green
mass · 1969
1 sentence

1996This is consistent with the statement in Carney v. Springfield, 403 Mass. 604, 610 (1988): “In Massachusetts, art. 12 of the Declaration of Rights requires transactional immunity to supplant the privilege against self-incrimination, even in the context of public employment.” See id. at 611 , stating that Baker v. Lawrence, 379 Mass. 322 (1979), Silverio v. Municipal Court of the City of Boston, 355 Mass. 623 , cert, denied, 396 U.S. 878 (1969), and Patch v. Mayor of Revere, 397 Mass. 454 (1986), are all inapposite as no claim was made in those cases under art. 12.

11996–1996
Silverio v. Municipal Court of Boston green
scotus · 1969
1 sentence

1996This is consistent with the statement in Carney v. Springfield, 403 Mass. 604, 610 (1988): “In Massachusetts, art. 12 of the Declaration of Rights requires transactional immunity to supplant the privilege against self-incrimination, even in the context of public employment.” See id. at 611 , stating that Baker v. Lawrence, 379 Mass. 322 (1979), Silverio v. Municipal Court of the City of Boston, 355 Mass. 623 , cert, denied, 396 U.S. 878 (1969), and Patch v. Mayor of Revere, 397 Mass. 454 (1986), are all inapposite as no claim was made in those cases under art. 12.

11996–1996
Patch v. Mayor of Revere green
mass · 1986
1 sentence

1996This is consistent with the statement in Carney v. Springfield, 403 Mass. 604, 610 (1988): “In Massachusetts, art. 12 of the Declaration of Rights requires transactional immunity to supplant the privilege against self-incrimination, even in the context of public employment.” See id. at 611 , stating that Baker v. Lawrence, 379 Mass. 322 (1979), Silverio v. Municipal Court of the City of Boston, 355 Mass. 623 , cert, denied, 396 U.S. 878 (1969), and Patch v. Mayor of Revere, 397 Mass. 454 (1986), are all inapposite as no claim was made in those cases under art. 12.

11996–1996
Commonwealth v. Jones green
mass · 1977
1 sentence

1980“Such a shift may be proper if there is a ‘manifest disparity in convenience of proof and opportunity for knowledge as, for instance, where a general prohibition is applicable to everyone who is unable to bring himself within the range of an exception’.” Commonwealth v. Jones, supra at 408 , quoting from Morrison v. California, 291 U.S. 82, 91 (1934).

11980–1980
Finance Commission of Boston v. McGrath green
mass · 1962
1 sentence

1965“Section 18 amply empowers the commission (as a continuing independent body charged with watching city operations constantly and reporting what it observes to ‘the mayor, the city council, the governor or the general court,’ as may be appropriate) to investigate at least those matters which, in its opinion entertained reasonably, have substantial relevance to the proper management of the city’s affairs and the appropriate conduct of city employees in relation to matters in which the city has an interest.” Finance Commn. of Boston v. McGrath, 343 Mass. 754, 760 .

11965–1965

Statutes the citing opinions construe

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

CA 55 (1966–2025) NY 31 (1864–2026) OK 23 (1915–2020) IL 16 (1905–2024) TX 14 (1993–2016) MA 14 (1927–2026) PA 10 (1960–2023) NJ 10 (1974–2021) KY 10 (1931–2021) MI 10 (1916–2023) MO 8 (1899–2025) IN 8 (1990–2023) OR 8 (1987–2025) TN 8 (2000–2016) NC 8 (1978–2023) LA 8 (1909–2020) CO 8 (1990–2021) AL 7 (1912–2011) FL 7 (1985–2025) WA 7 (1989–2017) WI 7 (1976–2023) UT 6 (1990–2020) ME 6 (1973–2017) KS 5 (1896–1983) MN 5 (1939–2024) AZ 5 (1995–2023) CT 5 (1959–2006) OH 5 (1939–2021) DC 4 (1975–2007) WV 4 (2000–2016) MD 4 (1902–1996) VI 3 (2009–2017) VT 3 (1921–2026) NE 3 (1957–2023) ID 3 (1928–2022) NM 2 (2010–2011) VA 2 (1984–1987) SD 2 (1969–2000) DE 2 (1963–2025) GA 2 (1941–2021) IA 2 (2022–2022)

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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