low bar (Massachusetts) · Go Syfert
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low bar in Massachusetts

9 Massachusetts opinions name it 3 courts 1983–2025 4 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 (8)

CaseFollowedCited
Miranda v. Arizonagreen
scotus · 1966 · cited in 2 Massachusetts opinions naming this issue, 2012–2025
2 sentences

2025In its seminal decision in Miranda v. Arizona, 384 U.S. 436, 473-474 (1966), the United States Supreme Court intentionally set a low bar for the invocation of the right to remain silent: "If the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease." See Clarke, 461 Mass. at 342 .

2012The United States Supreme Court’s decision in Miranda set a low bar for invocation of the right to remain silent: “If the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease.” Miranda, supra at 473-474 .

12
Commonwealth v. Martingreen
mass · 2005 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025The constitutionally based prophylactic rule announced in Miranda protects rights guaranteed under both the Fifth Amendment to the United States Constitution[7] and art. 12 of the Massachusetts Declaration of Rights.[8] Commonwealth v. Martin, 444 Mass. 213, 218 (2005).

11
Doe, SORB No. 380316 v. Sex Offender Registry Boardgreen
mass · 2015 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
2 sentences

2023See Doe, Sex Offender Registry Bd. No. 380316 v. Sex Offender Registry Bd., 473 Mass. 297, 309 (2015) ("deprivation of more extensive private interests requires greater procedural protections").

2023See Doe, Sex Offender Registry Bd. No. 380316 v. Sex Offender Registry Bd., 473 Mass. 297, 309 (2015) ("deprivation of more extensive private interests requires greater procedural protections").

11
In re the Estate of Morettigreen
massappct · 2007 · cited in 1 Massachusetts opinions naming this issue, 2021–2021
1 sentence

2021See, e.g., Estate of Moretti, 69 Mass. App. Ct. 642, 652-659 (2007) (sufficient evidence of undue influence). 8.

11
Dowling v. United Statesgreen
scotus · 1990 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015Thus, the fact that the defendant is forced to relitigate his participation in a prior criminal offense under a low standard of proof combined with the inherently prejudicial nature of such evidence increases the risk that the jury erroneously will convict the defendant of the presently charged offense.” (Citations omitted.) Dowling, 493 U.S. at 361-362 (Brennan, J., dissenting).

2015“Moreover, because of the significance a jury may place on evidence of a prior criminal offense, presenting a defense against that offense may be as burdensome as defending against the presently charged offense.” Id. at 362 (Brennan, J., dissenting). “[Because] the lower standard of proof makes it easier for the jury to conclude that the defendant committed the prior offense, the defendant is essentially forced to present affirmative evidence to rebut the *547 contention that he committed that offense.” Id.

11
Gerstein v. Superintendent Search Screening Committeegreen
mass · 1989 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
1 sentence

2008See Gerstein v. Superintendent Search Screening Comm., 405 Mass. 465, 469-70 (1989) (setting a low standard by including committee interviews with candidates for the position of superintendent within the definition of “deliberations”).

11
Canavan's Casegreen
mass · 2000 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See Canavan’s Case, 432 Mass. 304, 315 (2000) (“We cannot conclude that the . . . mere assertion that a methodology is reliable is sufficient to pass the Lanigan test absent any other evidence showing its reliability”).

11
Bobby Joe Olles v. United Statesgreen
ca8 · 1978 · cited in 1 Massachusetts opinions naming this issue, 1983–1983
1 sentence

1983Olles v. United States, 570 F.2d 817, 819 (8th Cir. 1978).

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. Clarke green
mass · 2012
1 sentence

2025In its seminal decision in Miranda v. Arizona, 384 U.S. 436, 473-474 (1966), the United States Supreme Court intentionally set a low bar for the invocation of the right to remain silent: "If the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease." See Clarke, 461 Mass. at 342 .

12025–2025
Trustees of Forbes Library v. Labor Relations Commission green
mass · 1981
1 sentence

2025Forbes, supra at 566 .

12025–2025
Wheelock College v. Massachusetts Commission Against Discrimination green
mass · 1976
1 sentence

2025We adopted the burden-shifting framework in recognition "that proof of unlawful discrimination rarely can be established by direct evidence and that an employer's seemingly arbitrary action or pretended explanation for [an action] should not be permitted to justify conduct which is in fact unlawfully discriminatory." Wheelock College, supra. Accordingly, the framework "lightens the employee's burden" by requiring the employer to produce evidence that "provides information and narrows the field of possible lawful reasons that the employee must address" once the employee has met the low bar requ

12025–2025

Where else courts name it

IL 45 (1987–2026) CA 39 (2002–2026) WI 37 (2012–2026) UT 36 (2008–2026) WA 27 (2008–2026) TX 23 (2014–2026) IN 19 (1991–2023) ME 19 (2006–2024) OR 16 (2009–2026) KY 15 (2007–2026) CO 14 (2007–2026) MD 13 (2012–2026) NC 12 (2005–2025) OH 12 (1916–2026) DE 11 (2015–2026) NY 11 (2014–2026) MA 9 (1983–2025) PA 8 (2010–2025) AZ 8 (1989–2025) IA 7 (1995–2025) CT 7 (1994–2026) GA 7 (1951–2026) MO 6 (2004–2022) MI 5 (2016–2022) SC 5 (2019–2026) VA 4 (1990–2023) LA 4 (1986–2018) NJ 4 (2014–2026) KS 3 (1993–2024) RI 3 (1998–2010) DC 3 (2021–2025) ID 2 (2022–2022) MT 2 (2009–2019) NV 2 (2020–2021) GU 2 (2023–2023) NM 2 (2001–2019) FL 2 (2012–2014) AR 2 (2025–2025)

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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