voluntariness doctrine (Vermont) · Go Syfert
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voluntariness doctrine in Vermont

13 Vermont opinions name it 2 courts 1984–2023 2 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 (7)

CaseFollowedCited
Miller v. Fentongreen
scotus · 1985 · cited in 3 Vermont opinions naming this issue, 2011–2016
2 sentences

2011At the same time, as the Supreme Court stressed in Ornelas , the “multi-faceted” nature of the voluntariness inquiry underscores the need for a body of binding case-law applying the consent-standard in a variety of individual cases, thereby providing “content . . . through application” and guidance to the police and the trial courts. 517 U.S. at 697 ; see also Miller, 474 U.S. at 114 (citing the imperative for independent review where “the relevant legal principle can be given meaning only through its application to the particular circumstances of a case”).

2011At the same time, as the Supreme Court stressed in Ornelas , the “multi-faceted” nature of the voluntariness inquiry underscores the need for a body of binding case-law applying the consent-standard in a variety of individual cases, thereby providing “content . . . through application” and guidance to the police and the trial courts. 517 U.S. at 697 ; see also Miller , 474 U.S. at 114 (citing the imperative for independent review where “the relevant legal principle can be given meaning only through its application to the particular circumstances of a case”).

33
State v. Zaccarogreen
vt · 1990 · cited in 1 Vermont opinions naming this issue, 2018–2018
2 sentences

2018See Zaccaro , 154 Vt. at 87 , 574 A.2d at 1259 .

2018See Zaccaro , 154 Vt. at 87 , 574 A.2d at 1259 .

11
Boykin v. Alabamagreen
scotus · 1969 · cited in 1 Vermont opinions naming this issue, 2017–2017
2 sentences

2017We then drew from the voluntariness standard articulated by the Supreme Court in Boykin v. Alabama , which requires courts receiving a guilty plea to canvas the defendant on the record to ensure that the plea was voluntary. 395 U.S. 238 , 243-44, 89 S.Ct. 1709 , 23 L.Ed.2d 274 (1969).

2017We then drew from the voluntariness standard articulated by the Supreme Court in Boykin v. Alabama , which requires courts receiving a guilty plea to canvas the defendant on the record to ensure that the plea was voluntary. 395 U.S. 238 , 243-44, 89 S.Ct. 1709 , 23 L.Ed.2d 274 (1969).

11
Reichenbach v. Kraska Enterprises, LLCgreen
connappct · 2008 · cited in 1 Vermont opinions naming this issue, 2010–2010
1 sentence

2010The voluntariness inquiry ensures that both parties have weighed and balanced the benefits and obligations of the settlement, and ultimately determined that their interests are best served by “voluntarily enter[ing] into an agreement setting their dispute or disputes at rest.” Reichenbach v. Kraska Enterprises, LLC, 938 A.2d 1238, 1247 (Conn. Ct. App. 2008).

11
Miranda v. Arizonagreen
scotus · 1966 · cited in 1 Vermont opinions naming this issue, 2005–2005
2 sentences

2005In Miranda, the Court confronted the deeply troubling practice of “incommunicado interrogation of individuals in a police-dominated atmosphere,” Miranda v. Arizona, 384 U.S. 436, 445 (1966), where officers created an interview environment designed “to subjugate the individual to the will of his examiner,” id. at 457 ; accord State v. Garbutt, 173 Vt. 277, 282 , 790 A.2d 444, 448 (2001).

2005In Miranda, the Court confronted the deeply troubling practice of “incommunicado interrogation of individuals in a police-dominated atmosphere,” Miranda v. Arizona, 384 U.S. 436, 445 (1966), where officers created an interview environment designed “to subjugate the individual to the will of his examiner,” id. at 457 ; accord State v. Garbutt, 173 Vt. 277, 282 , 790 A.2d 444, 448 (2001).

11
State v. Garbuttgreen
vt · 2001 · cited in 1 Vermont opinions naming this issue, 2005–2005
2 sentences

2005In Miranda, the Court confronted the deeply troubling practice of “incommunicado interrogation of individuals in a police-dominated atmosphere,” Miranda v. Arizona, 384 U.S. 436, 445 (1966), where officers created an interview environment designed “to subjugate the individual to the will of his examiner,” id. at 457 ; accord State v. Garbutt, 173 Vt. 277, 282 , 790 A.2d 444, 448 (2001).

2005In Miranda, the Court confronted the deeply troubling practice of “incommunicado interrogation of individuals in a police-dominated atmosphere,” Miranda v. Arizona, 384 U.S. 436, 445 (1966), where officers created an interview environment designed “to subjugate the individual to the will of his examiner,” id. at 457 ; accord State v. Garbutt, 173 Vt. 277, 282 , 790 A.2d 444, 448 (2001).

11
Culombe v. Connecticutgreen
scotus · 1961 · cited in 1 Vermont opinions naming this issue, 1984–1984
1 sentence

1984He cites Culombe v. Connecticut, 367 U.S. 568, 620-21 (1961), Davis v. North Carolina, 384 U.S. 737, 742 (1966), and other cases to the effect that “educational and mental shortcomings are relevant factors in the voluntariness analysis.” The motion was denied.

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 (8)

CaseCitedYears
State v. Leo Reynolds green
vt · 2016
2 sentences

2023Reynolds, 2016 VT 43 , ¶ 13.

2021Reynolds, 2016 VT 43 , ¶ 13.

32018–2023
Schneckloth v. Bustamonte green
scotus · 1973
2 sentences

2018State v. Reynolds , 2016 VT 43 , ¶ 13, 201 Vt. 574 , 145 A.3d 1256 (citing Schneckloth v. Bustamonte , 412 U.S. 218 , 226, 93 S.Ct. 2041 , 36 L.Ed.2d 854 (1973) ).

2018State v. Reynolds , 2016 VT 43 , ¶ 13, 201 Vt. 574 , 145 A.3d 1256 (citing Schneckloth v. Bustamonte , 412 U.S. 218 , 226, 93 S.Ct. 2041 , 36 L.Ed.2d 854 (1973) ).

22011–2018
United States v. Correa-Torres green
ca1 · 2003
1 sentence

2018Correa-Torres, 326 F.3d at 23 .

12018–2018
Ornelas v. United States green
scotus · 1996
2 sentences

2011At the same time, as the Supreme Court stressed in Ornelas , the “multi-faceted” nature of the voluntariness inquiry underscores the need for a body of binding case-law applying the consent-standard in a variety of individual cases, thereby providing “content . . . through application” and guidance to the police and the trial courts. 517 U.S. at 697 ; see also Miller, 474 U.S. at 114 (citing the imperative for independent review where “the relevant legal principle can be given meaning only through its application to the particular circumstances of a case”).

2011At the same time, as the Supreme Court stressed in Ornelas , the “multi-faceted” nature of the voluntariness inquiry underscores the need for a body of binding case-law applying the consent-standard in a variety of individual cases, thereby providing “content . . . through application” and guidance to the police and the trial courts. 517 U.S. at 697 ; see also Miller , 474 U.S. at 114 (citing the imperative for independent review where “the relevant legal principle can be given meaning only through its application to the particular circumstances of a case”).

12011–2011
Malloy v. Hogan green
scotus · 1964
2 sentences

2005Until Miranda , the Court continued to base its decisions excluding coerced confessions primarily on notions of due process, and it has not abandoned the voluntariness doctrine as a distinct body of law even as its focus has shifted to questions of police custody during suspect interrogation. 530 U.S. at 434 , 120 S.Ct. 2326 (citing Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964)). ¶ 34.

2005Until Miranda, the Court continued to base its decisions excluding coerced confessions primarily on notions of due process, and it has not abandoned the voluntariness doctrine as a distinct body of law even as its focus has shifted to questions of police custody during suspect interrogation. 530 U.S. at 434 (citing Malloy v. Hogan, 378 U.S. 1 (1964)). ¶ 34.

12005–2005
Dickerson v. United States red
scotus · 2000
2 sentences

2005Until Miranda , the Court continued to base its decisions excluding coerced confessions primarily on notions of due process, and it has not abandoned the voluntariness doctrine as a distinct body of law even as its focus has shifted to questions of police custody during suspect interrogation. 530 U.S. at 434 , 120 S.Ct. 2326 (citing Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964)). ¶ 34.

2005Until Miranda, the Court continued to base its decisions excluding coerced confessions primarily on notions of due process, and it has not abandoned the voluntariness doctrine as a distinct body of law even as its focus has shifted to questions of police custody during suspect interrogation. 530 U.S. at 434 (citing Malloy v. Hogan, 378 U.S. 1 (1964)). ¶ 34.

12005–2005
Joseph Wilson v. David Harris, Superintendent, Green Haven Correctional Facility green
ca2 · 1979
1 sentence

1989Further, we note that the Wilson court did not mandate the personal presence of the defendant in that case in making its determination that the defendant had intentionally waived his constitutional right to be present at trial. 595 F.2d at 104 .

11989–1989
Davis v. North Carolina green
scotus · 1966
1 sentence

1984He cites Culombe v. Connecticut, 367 U.S. 568, 620-21 (1961), Davis v. North Carolina, 384 U.S. 737, 742 (1966), and other cases to the effect that “educational and mental shortcomings are relevant factors in the voluntariness analysis.” The motion was denied.

11984–1984

Where else courts name it

TX 134 (1974–2026) AZ 122 (1964–2026) NY 76 (1965–2026) CA 63 (1978–2026) AL 59 (1973–2024) MN 59 (1978–2026) TN 51 (1969–2026) PA 49 (1975–2026) IL 49 (1975–2025) MD 47 (1963–2025) IN 42 (1975–2024) FL 38 (1971–2021) CO 37 (1971–2026) OH 37 (1984–2025) MS 37 (1985–2025) MA 37 (1976–2026) GA 32 (1978–2025) NJ 32 (1967–2026) ME 31 (1976–2024) WA 27 (1976–2026) IA 26 (1974–2023) MI 26 (1969–2025) KS 23 (1983–2025) LA 22 (1977–2014) OR 20 (1970–2023) WI 20 (1978–2025) HI 17 (1964–2025) CT 16 (1978–2022) NC 14 (1968–2018) AR 14 (1980–2010) VT 13 (1984–2023) DC 13 (1981–2022) VA 12 (1992–2024) KY 12 (1994–2025) SC 12 (1996–2024) MO 10 (1973–2017) WV 10 (1977–2026) DE 9 (1967–2025) NM 9 (1978–2021) UT 9 (1986–2019) MT 8 (1988–2024) SD 8 (1981–2025) WY 8 (1995–2021) ID 7 (1985–2023) NE 7 (1985–2025) AK 6 (1987–2020) ND 6 (1977–2016) RI 5 (1985–2013) NV 5 (1980–2022) NH 4 (1984–2021) OK 4 (1972–1995)

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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