White rule (Michigan) · Go Syfert
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White rule in Michigan

8 Michigan opinions name it 2 courts 1973–2025 1 in the last five years

The cases below were cited by Michigan 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
Crampton v. 54-A District Judgegreen
mich · 1976 · cited in 2 Michigan opinions naming this issue, 1981–1984
2 sentences

1984This application of the White principle was specifically approved in Crampton, supra, p 502, fn 8 .

1981Crampton v 54-A Dist Judge, 397 Mich 489 ; 245 NW2d 28 (1976).

12
People v. Adamsgreen
michctapp · 1999 · cited in 1 Michigan opinions naming this issue, 2025–2025
2 sentences

2025See Adams, 232 Mich App at 133-134 .

2025See Adams, 232 Mich App at 133-134 .

11
Albernaz v. United Statesgreen
scotus · 1981 · cited in 1 Michigan opinions naming this issue, 2004–2004
2 sentences

2004See n 11 supra. Moreover, it should be noted that the Albernaz Court specifically stated that "[i]t is well settled that a single transaction can give rise to distinct offenses under separate statutes without violating the Double Jeopardy Clause." Id. at 344 n. 3, 101 S.Ct. 1137 . [31] The dissent asserts that our holdings in Parrow, supra, and Ochotski, supra, illustrate the evil that will spring from abrogation of the White rule.

2004See n 11 supra. Moreover, it should be noted that the Albernaz Court specifically stated that "[i]t is well settled that a single transaction can give rise to distinct offenses under separate statutes without violating the Double Jeopardy Clause." Id. at 344 n. 3, 101 S.Ct. 1137 . [31] The dissent asserts that our holdings in Parrow, supra, and Ochotski, supra, illustrate the evil that will spring from abrogation of the White rule.

11
Bellis v. United Statesgreen
scotus · 1974 · cited in 1 Michigan opinions naming this issue, 1984–1984
2 sentences

1984Bellis v United States, 417 US 85 ; 94 S Ct 2179 ; 40 L Ed 2d 678 (1974), dispels any suggestion that the White test depends solely on the size of the organization.

1984Bellis v United States, 417 US 85 ; 94 S Ct 2179 ; 40 L Ed 2d 678 (1974), dispels any suggestion that the White test depends solely on the size of the organization.

11
People v. D'Angelogreen
mich · 1977 · cited in 1 Michigan opinions naming this issue, 1981–1981
2 sentences

1981In People v D’Angelo, 401 Mich 167, 179, 182 ; 257 NW2d 655 (1977), we stressed the fact that entrapment is a conceptually unique defense: "When an accused claims entrapment he is asserting, in essence, entitlement to the benefit of a judicial policy that his claim, if true, is a bar to the prosecution of the case.

1981In People v D’Angelo, 401 Mich 167, 179, 182 ; 257 NW2d 655 (1977), we stressed the fact that entrapment is a conceptually unique defense: "When an accused claims entrapment he is asserting, in essence, entitlement to the benefit of a judicial policy that his claim, if true, is a bar to the prosecution of the case.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
People v. Parrow neutral
mich · 1890
2 sentences

2004The dissent asserts that our holdings in Parrow, supra, and Ochotski, supra, illustrate the evil that will spring from abrogation of the White rule.

2004The dissent asserts that our holdings in Parrow, supra, and Ochotski, supra, illustrate the evil that will spring from abrogation of the White rule.

12004–2004
People v. Ochotski green
mich · 1898
2 sentences

2004The dissent asserts that our holdings in Parrow, supra, and Ochotski, supra, illustrate the evil that will spring from abrogation of the White rule.

2004The dissent asserts that our holdings in Parrow, supra, and Ochotski, supra, illustrate the evil that will spring from abrogation of the White rule.

12004–2004
Menna v. New York green
scotus · 1975
2 sentences

1976The United States Supreme Court has held that a defendant is not precluded from raising on appeal a double jeopardy defense even though he pled guilty. 7 Menna v New York, 423 US 61, fn 2 ; 96 S Ct 241 ; 46 L Ed 2d 195 (1975).

1976The United States Supreme Court has held that a defendant is not precluded from raising on appeal a double jeopardy defense even though he pled guilty. 7 Menna v New York, 423 US 61, fn 2 ; 96 S Ct 241 ; 46 L Ed 2d 195 (1975).

11976–1976
State v. Saidel green
conn · 1970
2 sentences

1973If thé state, at the first appearance (as distinguished from arraignment) following the bindover, could gain the dismissal of the motion attacking the validity of the arrest (on the grounds of White) by pointing to the results of the preliminary, the beneficial effect of the White ruling on prosecution practices would be almost completely negated.” See State v Saidel, supra; State v Licari, supra. In the instant case, defendant did not object to the validity of the arrest warrant until appeal.

1973If thé state, at the first appearance (as distinguished from arraignment) following the bindover, could gain the dismissal of the motion attacking the validity of the arrest (on the grounds of White) by pointing to the results of the preliminary, the beneficial effect of the White ruling on prosecution practices would be almost completely negated.” See State v Saidel, supra; State v Licari, supra. In the instant case, defendant did not object to the validity of the arrest warrant until appeal.

11973–1973
State v. Licari red
conn · 1965
2 sentences

1973If thé state, at the first appearance (as distinguished from arraignment) following the bindover, could gain the dismissal of the motion attacking the validity of the arrest (on the grounds of White) by pointing to the results of the preliminary, the beneficial effect of the White ruling on prosecution practices would be almost completely negated.” See State v Saidel, supra; State v Licari, supra. In the instant case, defendant did not object to the validity of the arrest warrant until appeal.

1973If thé state, at the first appearance (as distinguished from arraignment) following the bindover, could gain the dismissal of the motion attacking the validity of the arrest (on the grounds of White) by pointing to the results of the preliminary, the beneficial effect of the White ruling on prosecution practices would be almost completely negated.” See State v Saidel, supra; State v Licari, supra. In the instant case, defendant did not object to the validity of the arrest warrant until appeal.

11973–1973
State Ex Rel. White v. Simpson green
wis · 1965
2 sentences

1973The reason a defendant should be permitted to raise the invalidity of his arrest under White [State ex rel White v Simpson, 28 Wis 2d 590 ; 137 NW2d 391 (1965)] when he appears in the trial court and prior to actual arraignment and entry of a plea, is to enforce the purpose of the White rule which is to assure that arrest warrants will be issued only on probable cause as determined by a neutral magistrate.

1973The reason a defendant should be permitted to raise the invalidity of his arrest under White [State ex rel White v Simpson, 28 Wis 2d 590 ; 137 NW2d 391 (1965)] when he appears in the trial court and prior to actual arraignment and entry of a plea, is to enforce the purpose of the White rule which is to assure that arrest warrants will be issued only on probable cause as determined by a neutral magistrate.

11973–1973

Where else courts name it

TN 48 (2004–2025) OH 38 (1981–2024) WA 38 (1965–2026) CA 38 (1970–2026) GA 35 (1993–2025) TX 33 (1993–2024) MS 27 (1968–2025) PA 26 (1968–2025) IN 22 (1979–2026) FL 18 (1980–2018) IL 16 (1980–2025) VA 13 (1981–2026) IA 10 (2002–2024) WI 9 (1969–2026) MO 9 (1954–2025) MI 8 (1973–2025) AL 8 (1992–2013) NY 8 (1988–2024) KS 7 (1984–2022) AR 7 (2004–2022) MN 6 (1987–2014) AZ 6 (1981–2024) MT 6 (1981–2023) KY 6 (2015–2024) DC 6 (1994–2026) ME 5 (1983–2022) WY 5 (1972–2026) NV 5 (1983–2019) LA 4 (1967–2011) DE 4 (2018–2022) OR 4 (1996–2011) NJ 4 (1964–2024) MA 4 (1968–2023) HI 3 (1999–2024) NC 3 (1986–2005) ID 3 (2011–2019) NE 3 (1991–2022) WV 3 (2011–2012) MD 3 (1967–2006) CT 3 (1994–2018) OK 2 (1995–1996) UT 2 (1994–2020) ND 2 (1982–1989) SC 2 (2003–2019) AK 2 (2007–2013) CO 2 (1967–2025)

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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