voluntariness of a Miranda waiver (Massachusetts) · Go Syfert
← Massachusetts issues

voluntariness of a Miranda waiver in Massachusetts

10 Massachusetts opinions name it 3 courts 2000–2025 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 (6)

CaseFollowedCited
Commonwealth v. Edwardsgreen
mass · 1995 · cited in 6 Massachusetts opinions naming this issue, 2000–2025
2 sentences

2024Holmes then responded that she understood her rights and proceeded to make subsequent 10 statements, including an admission that she drove from Braintree to Stoughton around midnight.3 "Although the voluntariness of a Miranda waiver and the voluntariness of a particular statement made during custodial interrogation 'are separate and distinct issues,' the 'test' for both is 'essentially the same.'" Commonwealth v. Newson, 471 Mass. 222, 229 (2015), quoting Commonwealth v. Edwards, 420 Mass. 666, 670 (1995).

2015Although the voluntariness of a Miranda waiver and the voluntariness of a particular statement made during custodial interrogation “are separate and distinct issues,” the “test” for both is “essentially the same.” Commonwealth v. Edwards, 420 Mass. 666, 670 (1995).

56
Commonwealth v. LeBeaugreen
mass · 2008 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024Although the voluntariness of a Miranda waiver and the voluntariness of a statement to police are distinct inquiries, in both cases the issue on appeal is "whether the Commonwealth has proved, by a totality of the circumstances, that [the defendant] made a voluntary, knowing, and intelligent waiver of his rights, and that his statements were otherwise voluntary." Commonwealth v. Gallett, 481 Mass. 662, 655 (2019), quoting Commonwealth v. LeBeau, 451 Mass. 244, 254-255 (2008).

11
Commonwealth v. Gallettgreen
mass · 2019 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024Although the voluntariness of a Miranda waiver and the voluntariness of a statement to police are distinct inquiries, in both cases the issue on appeal is "whether the Commonwealth has proved, by a totality of the circumstances, that [the defendant] made a voluntary, knowing, and intelligent waiver of his rights, and that his statements were otherwise voluntary." Commonwealth v. Gallett, 481 Mass. 662, 655 (2019), quoting Commonwealth v. LeBeau, 451 Mass. 244, 254-255 (2008).

11
Commonwealth v. Newsongreen
mass · 2015 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
2 sentences

2024Holmes then responded that she understood her rights and proceeded to make subsequent 10 statements, including an admission that she drove from Braintree to Stoughton around midnight.3 "Although the voluntariness of a Miranda waiver and the voluntariness of a particular statement made during custodial interrogation 'are separate and distinct issues,' the 'test' for both is 'essentially the same.'" Commonwealth v. Newson, 471 Mass. 222, 229 (2015), quoting Commonwealth v. Edwards, 420 Mass. 666, 670 (1995).

2024That test is whether "in light of the totality of the circumstances surrounding the making of the statement[s], the will of the defendant was overborne to the extent that the statement was not the result of a free and voluntary act." Newson, supra at 229-230 , quoting Tremblay, 460 Mass. at 207 .

11
Commonwealth v. Jacksongreen
mass · 2000 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
1 sentence

2007Commonwealth v. Jackson, 432 Mass. 82, 85-86 (2000).

11
Commonwealth v. Rodriguezgreen
mass · 1997 · cited in 1 Massachusetts opinions naming this issue, 2003–2003
1 sentence

2003The defendant asserts that his age, his education, and his discomfort at the time of the interrogation combined to render his waiver involuntary. 3 Although it is the Commonwealth’s burden to establish the voluntariness of a Miranda waiver beyond a reasonable doubt, see id., the motion judge determined that that burden had been met, and we see nothing in the totality of the circumstances surrounding the waiver, see Commonwealth v. Rodriguez, 425 Mass. 361, 366 (1997), that would justify a contrary ruling.

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 (3)

CaseCitedYears
Commonwealth v. Tremblay green
mass · 2011
1 sentence

2024That test is whether "in light of the totality of the circumstances surrounding the making of the statement[s], the will of the defendant was overborne to the extent that the statement was not the result of a free and voluntary act." Newson, supra at 229-230 , quoting Tremblay, 460 Mass. at 207 .

12024–2024
Commonwealth v. Woodbine green
mass · 2012
1 sentence

2018Commonwealth v. Woodbine , 461 Mass. 720 , 729 (2012).

12018–2018
Commonwealth v. Todd green
mass · 1990
1 sentence

2003The defendant asserts that his age, his education, and his discomfort at the time of the interrogation combined to render his waiver involuntary. 3 Although it is the Commonwealth’s burden to establish the voluntariness of a Miranda waiver beyond a reasonable doubt, see id., the motion judge determined that that burden had been met, and we see nothing in the totality of the circumstances surrounding the waiver, see Commonwealth v. Rodriguez, 425 Mass. 361, 366 (1997), that would justify a contrary ruling.

12003–2003

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 278, § 33E (5) 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

OH 12 (2002–2024) MA 10 (2000–2025) CA 6 (1979–2023) IN 6 (2011–2025) CO 4 (1990–2026) FL 4 (1990–1994) MI 3 (2013–2025) NJ 3 (2018–2026) MT 3 (2007–2008) MD 2 (1993–2004) TN 2 (2010–2014) DE 2 (1996–2017) MN 2 (1998–2002) KS 2 (2007–2013) NY 2 (2004–2004) SD 2 (2002–2008)

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.

← Caselaw search · G Cite Topics · Brief Check