effectiveness waiver (District of Columbia) · Go Syfert
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effectiveness waiver in District of Columbia

8 District of Columbia opinions name it 1 courts 1976–2022 1 in the last five years

The cases below were cited by District of Columbia 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
Missouri v. Seibertgreen
scotus · 2004 · cited in 2 District of Columbia opinions naming this issue, 2015–2022
2 sentences

2022See id. at 1052- 54. 14 Accordingly, Justice Kennedy’s Seibert concurrence, having required deliberateness, does not engage in a comprehensive inquiry into effectiveness but asks only whether curative measures were taken. 542 U.S. at 621-22 (Kennedy, J., concurring). 21 should suppress the confession.”); United States v. Ray, 803 F.3d 244, 267-68 (6th Cir. 2015) (reading the Seibert plurality and Justice Kennedy’s Seibert concurrence as “recogniz[ing] that Miranda warnings usually will be ineffective in a successive interrogation that is ‘close in time and similar in content’ to the pre-Mirand

2015But the detective’s coercive statements also—first— undermined the effectiveness of the warning itself. 11 While Justice Kennedy agreed with the Seibert plurality that Miranda warnings may not be delivered in a manner that vitiates their effectiveness, he was of the view that whether the police violated Miranda additionally turned on whether the interrogating officer deliberately subverted the warnings. 542 U.S. at 622 (Kennedy, J., concurring).

22
United States v. Abu Khatallahgreen
dcd · 2017 · cited in 1 District of Columbia opinions naming this issue, 2022–2022
1 sentence

2022Detective Queen’s stated reason for delaying the Miranda warnings is consistent with an intent to undermine the warnings. 10 She testified at the 9 Nor has the government argued that the questioning was “for a purpose distinct from criminal prosecution,” cf. United States v. Abu Khatallah, 275 F. Supp. 3d 32, 63 (D.D.C. 2017), a category of cases we need not address today. 10 The officer’s account is not, of course, the only factor to be considered in assessing deliberateness.

11
United States v. Alvin Raygreen
ca6 · 2015 · cited in 1 District of Columbia opinions naming this issue, 2022–2022
1 sentence

2022See id. at 1052- 54. 14 Accordingly, Justice Kennedy’s Seibert concurrence, having required deliberateness, does not engage in a comprehensive inquiry into effectiveness but asks only whether curative measures were taken. 542 U.S. at 621-22 (Kennedy, J., concurring). 21 should suppress the confession.”); United States v. Ray, 803 F.3d 244, 267-68 (6th Cir. 2015) (reading the Seibert plurality and Justice Kennedy’s Seibert concurrence as “recogniz[ing] that Miranda warnings usually will be ineffective in a successive interrogation that is ‘close in time and similar in content’ to the pre-Mirand

11
United States v. Tashiri Wayne Williamsgreen
ca9 · 2006 · cited in 1 District of Columbia opinions naming this issue, 2022–2022
1 sentence

2022See id. at 1052- 54. 14 Accordingly, Justice Kennedy’s Seibert concurrence, having required deliberateness, does not engage in a comprehensive inquiry into effectiveness but asks only whether curative measures were taken. 542 U.S. at 621-22 (Kennedy, J., concurring). 21 should suppress the confession.”); United States v. Ray, 803 F.3d 244, 267-68 (6th Cir. 2015) (reading the Seibert plurality and Justice Kennedy’s Seibert concurrence as “recogniz[ing] that Miranda warnings usually will be ineffective in a successive interrogation that is ‘close in time and similar in content’ to the pre-Mirand

11
United States v. Maynard Francis Hayesgreen
ca4 · 1967 · cited in 1 District of Columbia opinions naming this issue, 1976–1976
1 sentence

1976As one court has stated : Just as the mere signing of a boilerplate statement to the effect that a defendant is knowingly waiving his rights will not discharge the - government’s burden, so the mere absence of such a statement will not preclude as a matter of law the possibility of an effective waiver. [United States v. Hayes, 385 F.2d 375, 377 (4th Cir. 1967), cert denied, 390 U.S. 1006 , 88 S.Ct. 1250 , 20 L.Ed.2d 106 (1968).] 4 Coupled with this lack of factors supporting appellant’s contention of involuntariness is the fact that the trial judge had both the benefit of hearing and evaluatin

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Neuman v. Neumangreen
dc · 1977 · cited in 1 District of Columbia opinions naming this issue, 1995–1995
1 sentence

1995See Neuman v. Neuman, 377 A.2d 393, 398 (D.C. 1977) ("rules of discovery are limited by Rule 26(b), which imposes a relevancy standard upon any matter that a party seeks to discover") (citations and footnote omitted). [11] In Arthur Treacher's, the court criticized this view on the basis that (1) it would be elementary to hone the questions to require greater and greater specificity regarding the matter discussed so as to avoid altogether the effectiveness of the privilege; and (2) the responses would be of little benefit to an opponent or the court if they were limited to the most general ter

11

Also cited on this issue (11)

CaseCitedYears
Hawkins v. United States green
dc · 1978
2 sentences

1985Singer; Adams, 317 U.S. at 277-78 , 63 S.Ct. at 240-41 ; Patton, 281 U.S. at 312 , 50 S.Ct. at 263 ; Hawkins v. United States, 385 A.2d 744 , 746 n. 4 (D.C.1978); D.C.

1985Singer ; Adams, 317 U.S. at 277-78 , 63 S.Ct. at 240-41 ; Patton, 281 U.S. at 312 , 50 S.Ct. at 263 ; Hawkins v. United States, 385 A.2d 744 , 746 n. 4 (D.C.1978); D.C.

21985–1985
Patton v. United States red
scotus · 1930
2 sentences

1985Singer; Adams, 317 U.S. at 277-78 , 63 S.Ct. at 240-41 ; Patton, 281 U.S. at 312 , 50 S.Ct. at 263 ; Hawkins v. United States, 385 A.2d 744 , 746 n. 4 (D.C.1978); D.C.

1985Singer; Adams, 317 U.S. at 277-78 , 63 S.Ct. at 240-41 ; Patton, 281 U.S. at 312 , 50 S.Ct. at 263 ; Hawkins v. United States, 385 A.2d 744 , 746 n. 4 (D.C.1978); D.C.

21985–1985
Adams v. United States Ex Rel. McCann green
scotus · 1943
2 sentences

1985Singer; Adams, 317 U.S. at 277-78 , 63 S.Ct. at 240-41 ; Patton, 281 U.S. at 312 , 50 S.Ct. at 263 ; Hawkins v. United States, 385 A.2d 744 , 746 n. 4 (D.C.1978); D.C.

1985Singer; Adams, 317 U.S. at 277-78 , 63 S.Ct. at 240-41 ; Patton, 281 U.S. at 312 , 50 S.Ct. at 263 ; Hawkins v. United States, 385 A.2d 744 , 746 n. 4 (D.C.1978); D.C.

21985–1985
Ford v. United States green
dc · 2007
1 sentence

2022The government has not argued that the delay in Mirandizing Mr. Kinney was unintentional—that, for example, Detective Queen forgot, or that she reasonably thought he was not in custody, cf., e.g., Ford, 931 A.2d at 1053 .9 The government thus must counter a presumption of illegitimacy and show that the delay was not intended to undermine the effectiveness of the warnings.

12022–2022
Gray v. Citizens Bank of Washington green
dc · 1992
1 sentence

1995Arthur Treacher's, 92 F.R.D. at 435 . [12] See note 10, supra. [1] See D.C.Code §§ 1-616.3 (1992); 1-2525, -2556; 11-1913 (1989); 36-220.9, -220.10 (1993); 36-342; 36-1217; 36-1307, -1310. [2] It is impossible to read Gray and reasonably conclude, as the dissent would, that a majority there intended future divisions to be free to adopt new exceptions to the doctrine. [1] In Gray, one member of the panel (concurring in affirmance of the trial court's dismissal of a complaint) agreed it would be "more seemly" to act en banc, 602 A.2d at 1099 ; another, relying on the specific factual allegations

11995–1995
In re Arthur Treacher's Franchisee Litigation green
paed · 1981
2 sentences

1995Arthur Treacher's, 92 F.R.D. at 435 . .

1995Arthur Treacher's, 92 F.R.D. at 435 . [12] See note 10, supra. [1] See D.C.Code §§ 1-616.3 (1992); 1-2525, -2556; 11-1913 (1989); 36-220.9, -220.10 (1993); 36-342; 36-1217; 36-1307, -1310. [2] It is impossible to read Gray and reasonably conclude, as the dissent would, that a majority there intended future divisions to be free to adopt new exceptions to the doctrine. [1] In Gray, one member of the panel (concurring in affirmance of the trial court's dismissal of a complaint) agreed it would be "more seemly" to act en banc, 602 A.2d at 1099 ; another, relying on the specific factual allegations

11995–1995
Singer v. United States green
scotus · 1965
2 sentences

1978Singer v. United States, 380 U.S. 24 , 85 S.Ct. 783 , 13 L.Ed.2d 630 (1965).

1978Singer v. United States, 380 U.S. 24 , 85 S.Ct. 783 , 13 L.Ed.2d 630 (1965).

11978–1978
Angarano v. United States green
dc · 1973
1 sentence

1977App., 312 A.2d 295 (1973), petition for reconsideration denied, 329 A.2d 453 (1974) (en banc), which adopted the effectiveness standard of Bruce v. United States, 126 U.S.App.D.C. 336 , 379 F.2d 113 (1967). 3 Al *4 though the Bruce standard was set in a collateral attack proceeding, this court has used that test in disposing of issues of counsel’s effectiveness raised on direct appeal.

11977–1977
Arthur Bruce v. United States green
cadc · 1967
2 sentences

1977App., 312 A.2d 295 (1973), petition for reconsideration denied, 329 A.2d 453 (1974) (en banc), which adopted the effectiveness standard of Bruce v. United States, 126 U.S.App.D.C. 336 , 379 F.2d 113 (1967). 3 Al *4 though the Bruce standard was set in a collateral attack proceeding, this court has used that test in disposing of issues of counsel’s effectiveness raised on direct appeal.

1977App., 312 A.2d 295 (1973), petition for reconsideration denied, 329 A.2d 453 (1974) (en banc), which adopted the effectiveness standard of Bruce v. United States, 126 U.S.App.D.C. 336 , 379 F.2d 113 (1967). 3 Al *4 though the Bruce standard was set in a collateral attack proceeding, this court has used that test in disposing of issues of counsel’s effectiveness raised on direct appeal.

11977–1977
Angarano v. United States green
dc · 1974
1 sentence

1977App., 312 A.2d 295 (1973), petition for reconsideration denied, 329 A.2d 453 (1974) (en banc), which adopted the effectiveness standard of Bruce v. United States, 126 U.S.App.D.C. 336 , 379 F.2d 113 (1967). 3 Al *4 though the Bruce standard was set in a collateral attack proceeding, this court has used that test in disposing of issues of counsel’s effectiveness raised on direct appeal.

11977–1977
Warren v. Waterville Urban Renewal Authority green
scotus · 1968
1 sentence

1976As one court has stated : Just as the mere signing of a boilerplate statement to the effect that a defendant is knowingly waiving his rights will not discharge the - government’s burden, so the mere absence of such a statement will not preclude as a matter of law the possibility of an effective waiver. [United States v. Hayes, 385 F.2d 375, 377 (4th Cir. 1967), cert denied, 390 U.S. 1006 , 88 S.Ct. 1250 , 20 L.Ed.2d 106 (1968).] 4 Coupled with this lack of factors supporting appellant’s contention of involuntariness is the fact that the trial judge had both the benefit of hearing and evaluatin

11976–1976

Statutes the citing opinions construe

DC § D.C. Code § 16-705 (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

NY 26 (1944–2019) NJ 21 (1911–2025) IL 17 (1975–2025) CA 17 (1969–2026) TX 16 (1985–2025) MI 14 (1976–2024) DE 14 (1981–2026) FL 14 (1972–2021) PA 14 (1954–2022) CO 13 (1986–2018) OH 12 (1991–2013) DC 8 (1976–2022) IA 7 (1966–2010) GA 7 (1993–2008) MD 7 (1972–2014) MA 6 (1981–2006) WA 6 (2008–2020) IN 6 (1997–2011) OK 5 (1938–2018) WI 5 (1987–2021) TN 5 (1958–2016) KS 5 (1974–2015) AZ 5 (1990–2022) LA 4 (1974–1998) AL 4 (1977–2016) ND 3 (1992–1995) OR 3 (1982–1990) VT 3 (1995–2007) CT 3 (2004–2017) MT 2 (1977–1978) AR 2 (1939–1973) MS 2 (2017–2017) MN 2 (1987–2003) NM 2 (2000–2023) SD 2 (1992–2011) UT 2 (1993–2015) NE 2 (2017–2017) RI 2 (1979–2012)

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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