written jury waiver (Massachusetts) · Go Syfert
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written jury waiver in Massachusetts

9 Massachusetts opinions name it 2 courts 1997–2023 1 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 (5)

CaseFollowedCited
Ciummei v. Commonwealthgreen
mass · 1979 · cited in 3 Massachusetts opinions naming this issue, 1997–2003
2 sentences

2003Id. at 508-509 .

1997Whenever a defendant in a criminal case decides to waive a trial by jury, he or she must file a written jury waiver, Commonwealth v. Wheeler, post 933, 934-935 (1997), and the judge must engage in a colloquy with the defendant in which, during the exchange, “the judge will advise the defendant of his constitutional right to a jury trial, and will satisfy himself that any waiver by the defendant is made voluntarily and intelligently.” Ciummei v. Commonwealth, 378 Mass. 504, 509 (1979).

23
Commonwealth v. Hendricksgreen
mass · 2008 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
1 sentence

2023Commonwealth v. Hendricks, 452 Mass. 97, 107-108 (2008).

11
Commonwealth v. Scogginsgreen
mass · 2003 · cited in 1 Massachusetts opinions naming this issue, 2006–2006
1 sentence

2006“A defendant’s ‘self-serving affidavits and assertions are not sufficient, on their own, to raise a substantial issue.’ Commonwealth v. Scoggins, 439 Mass. 571, 578 (2003).” Commonwealth v. Denis, 442 Mass. 617, 633-634 (2004).

11
Commonwealth v. Denisgreen
mass · 2004 · cited in 1 Massachusetts opinions naming this issue, 2006–2006
1 sentence

2006“A defendant’s ‘self-serving affidavits and assertions are not sufficient, on their own, to raise a substantial issue.’ Commonwealth v. Scoggins, 439 Mass. 571, 578 (2003).” Commonwealth v. Denis, 442 Mass. 617, 633-634 (2004).

11
Commonwealth v. Schofieldgreen
mass · 1984 · cited in 1 Massachusetts opinions naming this issue, 1997–1997
1 sentence

1997Thus, the defendant’s answers to the judge’s questions must indicate to the judge that the defendant has “ ‘a comprehension of the nature of the choice’ between a bench and jury trial.” Commonwealth v. Schofield, 391 Mass. 772, 775-776 (1984), quoting from Ciummei v. Commonwealth, supra at 510.

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 (4)

CaseCitedYears
Commonwealth v. Osborne green
mass · 2006
2 sentences

2019P. 19 (a), similarly calls for the waiver of the right to a jury trial to be in writing: "A case in which the defendant has the right to be tried by a jury shall be so tried unless the defendant waives a jury trial in writing with the approval of the court and files the waiver with the clerk ...." We have recognized the requirement of a written jury waiver as a "legislative safeguard" designed "to create a moment of pause and reflection on the part of a defendant that is concomitant with signing one's name to a formal declaration relinquishing that right." Commonwealth v. Osborne , 445 Mass. 7

2019P. 19 (a), similarly calls for the waiver of the right to a jury trial to be in writing: "A case in which the defendant has the right to be tried by a jury shall be so tried unless the defendant waives a jury trial in writing with the approval of the court and files the waiver with the clerk ...." We have recognized the requirement of a written jury waiver as a "legislative safeguard" designed "to create a moment of pause and reflection on the part of a defendant that is concomitant with signing one's name to a formal declaration relinquishing that right." Commonwealth v. Osborne , 445 Mass. 7

22018–2019
Commonwealth v. Pavao green
mass · 1996
2 sentences

2018Both forms, however, were executed five months before the colloquy and trial. 6 See Commonwealth v. Abreu , 391 Mass. 777 , 778 (1984) (colloquy must be conducted "contemporaneously with and before accepting any waiver"); Commonwealth v. Pavao , 423 Mass. 798 , 803 (1996).

2018The purpose of the written jury waiver by the defendant is to "assure[ ] that the ultimate decision regarding waiver of the jury be left to the defendant himself, not his counsel." Osborne , 445 Mass. at 781 , quoting Commonwealth v. Pavao , 423 Mass. 798 , 803 (1996).

22018–2018
Commonwealth v. Abreu green
mass · 1984
1 sentence

2018Both forms, however, were executed five months before the colloquy and trial. 6 See Commonwealth v. Abreu , 391 Mass. 777 , 778 (1984) (colloquy must be conducted "contemporaneously with and before accepting any waiver"); Commonwealth v. Pavao , 423 Mass. 798 , 803 (1996).

12018–2018
Commonwealth v. Wheeler green
massappct · 1997
1 sentence

2004Furthermore, we are not prepared to assume merely from the expansive language in a portion of the Collado opinion, ibid., that the Supreme Judicial Court intended sub silentio to supplant the bright-line rule reflected in our decision in Commonwealth v. Wheeler, supra, one year earlier.

12004–2004

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 263, § 6 (5) MA § Mass. Gen. Laws ch. 218, § 26A (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

IL 129 (1924–2026) TX 61 (1984–2026) OH 46 (1998–2026) OR 28 (1991–2025) NY 9 (1990–2005) MA 9 (1997–2023) PA 7 (2008–2025) FL 5 (1992–2015) WA 5 (2006–2020) IN 5 (1986–2014) MS 4 (1995–2019) WV 4 (1994–2010) MO 3 (2004–2022) ND 3 (1984–2003) IA 3 (2000–2003) CA 3 (2017–2024) KS 2 (2014–2020) NM 2 (2003–2017) NV 2 (2017–2017) AL 2 (1981–1987) NE 2 (1998–2001)

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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