right to make defense (Maryland) · Go Syfert
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right to make defense in Maryland

8 Maryland opinions name it 2 courts 1919–2025 1 in the last five years

The cases below were cited by Maryland 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 (13)

CaseFollowedCited
Faretta v. Californiagreen
scotus · 1975 · cited in 3 Maryland opinions naming this issue, 1997–2025
2 sentences

2025The Supreme Court explained that “[t]he Sixth Amendment does not provide merely that a defense shall be made for the accused; it grants to the accused personally the right to make his defense.” Id. at 819 .

2025The Supreme Court explained that the Sixth Amendment does not just provide that a defense shall be made for the accused; “it grants to the accused personally the right to make his defense.” Id. at 819 .

13
Snead v. Stategreen
md · 1979 · cited in 1 Maryland opinions naming this issue, 2025–2025
2 sentences

2025In Snead, 286 Md. at 128, 131 , 406 A.2d at 101, 103 , adopting the holding of the Supreme Court of the United States in Faretta that a defendant has a right to self- representation under the Sixth Amendment, we set forth a two-part test for determining compliance with the constitutional right.

2025In Snead, 286 Md. at 128, 131 , 406 A.2d at 101, 103 , adopting the holding of the Supreme Court of the United States in Faretta that a defendant has a right to self- representation under the Sixth Amendment, we set forth a two-part test for determining compliance with the constitutional right.

11
United States v. Carlos Manuel Parodi, United States of America v. Edwin Barton Conway, United States of America v. Robert Lee Lawsgreen
ca4 · 1983 · cited in 1 Maryland opinions naming this issue, 2012–2012
1 sentence

2012Based on the legislative history of Federal Rule 615, federal courts have held that the “officer or employee” exception includes a law enforcement officer, and therefore, the trial court “has a right to make an exception from a general rule of sequestration in favor of the chief investigating agent of the government involved in a trial.” United States v. Parodi, 703 F.2d 768, 773 (4th Cir.1983).

11
The United States of America v. Dennis L. Martingreen
ca6 · 1991 · cited in 1 Maryland opinions naming this issue, 2012–2012
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

11
United States v. Lorenzo Gonzalez, A/K/A \Titogreen
· 1991 · cited in 1 Maryland opinions naming this issue, 2012–2012
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

11
United States v. Riveragreen
ca2 · 1992 · cited in 1 Maryland opinions naming this issue, 2012–2012
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

11
United States v. Douglas D. Crabtree and Patrick H. Craygreen
ca7 · 1993 · cited in 1 Maryland opinions naming this issue, 2012–2012
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

11
United States v. Derrick Lamont Riddlegreen
ca8 · 1999 · cited in 1 Maryland opinions naming this issue, 2012–2012
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

11
Kann v. Kanngreen
md · 1997 · cited in 1 Maryland opinions naming this issue, 2006–2006
2 sentences

2006See Kann v. Kann, 344 Md. 689, 714-15 , 690 A.2d 509, 521 (1997).

2006See Kann v. Kann, 344 Md. 689, 714-15 , 690 A.2d 509, 521 (1997).

11
Carl Edwin Wiggins v. Dan v. McKaskle Acting Director, Texas Department of Correctionsgreen
ca5 · 1984 · cited in 1 Maryland opinions naming this issue, 1997–1997
1 sentence

1997See also McKaskle v. Wiggins, 465 U.S. 168, 170 , 104 S.Ct. 944, 947 , 79 L.Ed.2d 122, 128 (1984), aff'd on remand, 729 F.2d 1026 (5th Cir.Tex.1984), on reconsideration, 753 F.2d 1318 (5th Cir. Tex 1985), thus recognizing the right to self-representation as an independent right that is implicit in the protection afforded by that amendment.

11
Carl Edwin Wiggins v. Raymond K. Procunier, Director, Texas Department of Corrections, Respondentgreen
ca5 · 1985 · cited in 1 Maryland opinions naming this issue, 1997–1997
1 sentence

1997See also McKaskle v. Wiggins, 465 U.S. 168, 170 , 104 S.Ct. 944, 947 , 79 L.Ed.2d 122, 128 (1984), aff'd on remand, 729 F.2d 1026 (5th Cir.Tex.1984), on reconsideration, 753 F.2d 1318 (5th Cir. Tex 1985), thus recognizing the right to self-representation as an independent right that is implicit in the protection afforded by that amendment.

11
McKaskle v. Wigginsgreen
scotus · 1984 · cited in 1 Maryland opinions naming this issue, 1997–1997
2 sentences

1997See also McKaskle v. Wiggins, 465 U.S. 168, 170 , 104 S.Ct. 944, 947 , 79 L.Ed.2d 122, 128 (1984), aff'd on remand, 729 F.2d 1026 (5th Cir.Tex.1984), on reconsideration, 753 F.2d 1318 (5th Cir. Tex 1985), thus recognizing the right to self-representation as an independent right that is implicit in the protection afforded by that amendment.

1997See also McKaskle v. Wiggins, 465 U.S. 168, 170 , 104 S.Ct. 944, 947 , 79 L.Ed.2d 122, 128 (1984), aff'd on remand, 729 F.2d 1026 (5th Cir.Tex.1984), on reconsideration, 753 F.2d 1318 (5th Cir. Tex 1985), thus recognizing the right to self-representation as an independent right that is implicit in the protection afforded by that amendment.

11
Maryland Trust Co. v. Poffenbergergreen
md · 1929 · cited in 1 Maryland opinions naming this issue, 1986–1986
2 sentences

1986See, however, Maryland Trust Co. v. Poffenberger, 156 Md. 200, 206 , 144 A. 249 (1929), holding that "to entitle the surety to subrogation to the creditor’s rights, there must be a payment of the debt by the surety.

1986See, however, Maryland Trust Co. v. Poffenberger, 156 Md. 200, 206 , 144 A. 249 (1929), holding that "to entitle the surety to subrogation to the creditor’s rights, there must be a payment of the debt by the surety.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Hartman v. Pointer green
scotus · 1993
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

12012–2012
Lewis v. United States green
scotus · 1993
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

12012–2012
Sanchez v. United States green
scotus · 1993
1 sentence

2012Accord United States v. Riddle, 193 F.3d 995, 997 (8th Cir.1999) (“The exception has been interpreted to allow government case agents to sit at counsel table throughout the trial.”); United States v. Crabtree, 979 F.2d 1261, 1270 (7th Cir.1992) (“The agent could reasonably fit within the exemption provision of Rule 615, which does not authorize exclusion of an officer of the federal government designated as a representative of the government at trial.”), cert. denied, 510 U.S. 878 , 114 S.Ct. 216 , 217, 126 L.Ed.2d 173 (1993); United States v. Rivera, 971 F.2d 876, 889 (2d Cir. 1992) (“It is w

12012–2012
Arizona v. Fulminante green
scotus · 1991
2 sentences

2001Relying primarily on Arizona v. Fulminante, 499 U.S. 279 , 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991), he argues that prejudice should be presumed because the right of removal is a fundamental right or qualifies as a structural error not susceptible to establishing prejudice. 5 He further argues that assuming, arguendo, that he must prove prejudice, the denial of the right to make his defense before a different jury constitutes prejudice.

2001Relying primarily on Arizona v. Fulminante, 499 U.S. 279 , 111 S.Ct. 1246 , 113 L.Ed.2d 302 (1991), he argues that prejudice should be presumed because the right of removal is a fundamental right or qualifies as a structural error not susceptible to establishing prejudice. 5 He further argues that assuming, arguendo, that he must prove prejudice, the denial of the right to make his defense before a different jury constitutes prejudice.

12001–2001
Cecil v. Cecil green
md · 1862
1 sentence

1919It includes those who are directly interested in the subject-matter of the suit, knew of its pendency, and had the right to control, and direct, or defend it.” In the earlier case of Cecil v. Cecil, 19 Md. 72 , the Court stated the rule as to the parties to: be, “all who are directly interested in the subject-matter, and had a right to make defense, or to control the proceedings and to appeal from the judgment.

11919–1919

Where else courts name it

CA 45 (1956–2024) NY 25 (1882–2018) TX 23 (1883–2025) IN 20 (1947–2015) IA 18 (1892–2025) OR 16 (1887–2023) IL 12 (1907–2024) MI 12 (1895–2026) OH 12 (1949–2026) VA 11 (1874–2023) AL 11 (1887–2017) GA 11 (1913–2019) WA 10 (1927–2025) LA 10 (1953–2025) WI 10 (1960–2025) NJ 9 (1957–2004) KY 9 (1863–2014) NM 8 (1939–2013) MO 8 (1902–2016) FL 8 (1931–2025) MD 8 (1919–2025) DC 7 (1973–2022) PA 7 (1898–2018) MN 7 (1995–2004) AZ 7 (1928–2021) NC 6 (1972–2017) RI 5 (1980–2021) KS 5 (1878–2021) MS 5 (1981–2001) AR 5 (1944–2014) CT 5 (1946–2017) CO 5 (1890–2020) OK 5 (1911–2007) HI 4 (1899–1996) VT 4 (1891–2026) UT 3 (1990–2017) MA 3 (2008–2022) AK 3 (1984–1996) TN 3 (1988–2024) DE 3 (2009–2012) ID 3 (1986–2015) ME 3 (1978–2004) WY 2 (1978–1992) SC 2 (1924–2014) WV 2 (1903–1941) ND 2 (1910–1986)

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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