Massiah doctrine (Illinois) · Go Syfert
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Massiah doctrine in Illinois

8 Illinois opinions name it 1 courts 1967–2023 2 in the last five years

The cases below were cited by Illinois 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 (4)

CaseFollowedCited
The PEOPLE v. Lagardogreen
ill · 1968 · cited in 2 Illinois opinions naming this issue, 1973–1985
2 sentences

1985Indeed, most of the information was volunteered by defendant without any questioning or coercion by the Galvins.” This argument was rejected by the Illinois Supreme Court in People v. Lagardo (1968), 39 Ill. 2d 614, 616 , 237 N.E.2d 484 : “There has been some difference of opinion by the courts of this country as to whether the Massiah doctrine operates to exclude only incriminating post-indictment statements which are induced or deliberately elicited by police officers in the absence of counsel.

1985Indeed, most of the information was volunteered by defendant without any questioning or coercion by the Galvins.” This argument was rejected by the Illinois Supreme Court in People v. Lagardo (1968), 39 Ill. 2d 614, 616 , 237 N.E.2d 484 : “There has been some difference of opinion by the courts of this country as to whether the Massiah doctrine operates to exclude only incriminating post-indictment statements which are induced or deliberately elicited by police officers in the absence of counsel.

12
Texas v. Cobbgreen
scotus · 2001 · cited in 1 Illinois opinions naming this issue, 2023–2023
2 sentences

2023Texas v. Cobb, 532 U.S. 162, 166-67 (2001) (sixth amendment 5 right is offense specific; it cannot be invoked once for all future prosecutions, for it does not attach until a prosecution is commenced).

2023Texas v. Cobb, 532 U.S. 162, 166-67 (2001) (sixth amendment 5 right is offense specific; it cannot be invoked once for all future prosecutions, for it does not attach until a prosecution is commenced).

11
People v. Morgangreen
illappct · 1976 · cited in 1 Illinois opinions naming this issue, 1976–1976
2 sentences

1976App. 3d 10 , 350 N.E.2d 27, 34 (1976).

1976App. 3d 10 , 350 N.E.2d 27, 34 (1976).

11
The PEOPLE v. Halstromgreen
ill · 1966 · cited in 1 Illinois opinions naming this issue, 1973–1973
2 sentences

1973In People v. Lagardo, 39 Ill.2d 614, 616 (1968), the Massiah doctrine was interpreted “to exclude all post-indictment incriminating statements obtained in the absence of counsel, even when not deliberately elicited by interrogation or induced by misapprehension engendered by trickery or deception.” (See also, People v. Halstrom, 34 Ill.2d 20, 21-23 (1966).) In both of these cases the Court found that the presence of counsel had not been waived.

1973In People v. Lagardo, 39 Ill.2d 614, 616 (1968), the Massiah doctrine was interpreted “to exclude all post-indictment incriminating statements obtained in the absence of counsel, even when not deliberately elicited by interrogation or induced by misapprehension engendered by trickery or deception.” (See also, People v. Halstrom, 34 Ill.2d 20, 21-23 (1966).) In both of these cases the Court found that the presence of counsel had not been waived.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
People v. English green
ill · 2013
2 sentences

2023Defendant suggests that, because of the lack of such a motion and because of defense counsel’s failure to even cross-examine Smith, “it is unclear from the record what other portions of Smith’s testimony should have also been suppressed.” ¶ 69 Considering that defendant took a direct appeal, it is unclear why he waited until this postconviction proceeding to raise a Massiah claim. “[I]ssues that could have been raised on direct appeal, but were not, are forfeited.” People v. English, 2013 IL 112890, ¶ 22 .

2023Defendant suggests that, because of the lack of such a motion and because of defense counsel’s failure to even cross-examine Smith, “it is unclear from the record what other portions of Smith’s testimony should have also been suppressed.” ¶ 69 Considering that defendant took a direct appeal, it is unclear why he waited until this postconviction proceeding to raise a Massiah claim. “[I]ssues that could have been raised on direct appeal, but were not, are forfeited.” People v. English, 2013 IL 112890, ¶ 22 .

12023–2023
In Re Morgan green
illappct · 1975
2 sentences

1976App. 3d 193, 196-97 (1973), we concluded that the Massiah doctrine did not make all post-indictment incriminating statements obtained in the absence of counsel even though already retained per se inadmissible; buti that the right to counsel in those circumstances could be waived by a defendant acting knowingly and intelligently. 1 See also People v. Morgan, 35 Ill.

1976App. 3d 193, 196-97 (1973), we concluded that the Massiah doctrine did not make all post-indictment incriminating statements obtained in the absence of counsel even though already retained per se inadmissible; buti that the right to counsel in those circumstances could be waived by a defendant acting knowingly and intelligently. 1 See also People v. Morgan, 35 Ill.

11976–1976
United States v. Winston Valdemar Springer green
ca7 · 1972
2 sentences

1973(United States v. Springer, 460 F.2d 1344, 1350 .) Here there was no interrogation or ruse which was used in order to induce defendant to make an inculpatory statement.

1973(United States v. Springer, 460 F.2d 1344, 1350 .) Here there was no interrogation or ruse which was used in order to induce defendant to make an inculpatory statement.

11973–1973
Massiah v. United States green
scotus · 1964
2 sentences

1967Massiah v. United States, 377 US 201 .” The defendant suggests that the McLeod decision created an arena of far greater application of the Massiah doctrine to the States than the Massiah decision would, by itself, indicate.

1967Massiah v. United States, 377 US 201 .” The defendant suggests that the McLeod decision created an arena of far greater application of the Massiah doctrine to the States than the Massiah decision would, by itself, indicate.

11967–1967
People v. Lagardo neutral
illappct · 1967
1 sentence

1967People v. Lagardo, 82 Ill App2d 130, 226 NE2d 486 .

11967–1967

Where else courts name it

CA 43 (1977–2023) NY 9 (1966–2010) ID 9 (1981–2024) IL 8 (1967–2023) TX 6 (1969–2021) TN 6 (1980–2015) FL 6 (1991–2026) MA 4 (1971–2007) CT 4 (1972–2025) MD 4 (1966–1978) IA 3 (2015–2016) WI 2 (2010–2022) MI 2 (1983–1985)

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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