second step analysis (Massachusetts) · Go Syfert
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second step analysis in Massachusetts

7 Massachusetts opinions name it 2 courts 1981–2024 3 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
Massachusetts Electric Co. v. Massachusetts Commission Against Discriminationgreen
mass · 1978 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024Co. v. Massachusetts Comm'n Against Discrimination, 375 Mass. 160, 174 (1978).

11
Commonwealth v. Kilburngreen
mass · 2003 · cited in 1 Massachusetts opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., Kilburn , 438 Mass. at 359 , 780 N.E.2d 1237 (armed assault in dwelling with intent to commit felony capable of merging with resulting killing).

2018See, e.g., Kilburn , 438 Mass. at 359 , 780 N.E.2d 1237 (armed assault in dwelling with intent to commit felony capable of merging with resulting killing).

11
O'Coin's, Inc. v. Treasurer of the County of Worcestergreen
mass · 1972 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996We are not convinced that the deficits found to exist by the judge have the probative force to bring into play the second step of the inquiry as to the courthouses in Bristol and Norfolk (a determination of “the extent to which the facilities and related services are reasonably necessary to the fulfillment of the court’s constitutional duties,” Barnstable I, supra at 333), and what doubtlessly will be time-consuming additional litigation by other counties which might result in a constitutional clash between two branches of government.

11
Zapata Corp. v. Maldonadogreen
del · 1981 · cited in 1 Massachusetts opinions naming this issue, 1990–1990
2 sentences

1990Cognizant of the ever-present danger of structural bias, the Zapata court enunciated a second step to the analysis, in which the court would apply “its own independent business judgment.” Id.

1990This second step “is intended to thwart instances where corporate actions meet the criteria of step one, but the result does not appear to satisfy its spirit, or where corporate actions would simply prematurely terminate a stockholder grievance deserving of further consideration in the corporation’s interest.” Id. at 789.

11
Commonwealth v. Mainsgreen
mass · 1978 · cited in 1 Massachusetts opinions naming this issue, 1981–1981
1 sentence

1981See Commonwealth v. Mains, 374 Mass. 733, 738 (1978).

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 (3)

CaseCitedYears
New York State Rifle & Pistol Assn., Inc. v. Bruen green
scotus · 2022
2 sentences

2024At this second step of the analysis, Bruen requires us to determine whether "a challenged regulation addresses a general societal problem that has persisted since the [Eighteenth Century]." Id. at 26 .

2024If so, "the lack of distinctly similar historical regulation addressing that problem is relevant evidence that the challenged regulation is inconsistent with the Second Amendment." Id.

12024–2024
Commonwealth v. Fredette green
mass · 2018
1 sentence

2023"If the underlying predicate felony does not have an independent felonious purpose, the court must then undertake a second step in the analysis, to determine whether the felony merges with the killing." Fredette, 480 Mass. at 84 .

12023–2023
Commonwealth v. Saferian green
mass · 1974
1 sentence

1981When the tactical or strategic judgments of an attorney are called into question, the defendant must show the judgment to be “manifestly unreasonable,” Commonwealth v. Adams, 374 Mass. 728 (1978), which typically means the loss of “an otherwise available, substantial ground of defence.” Commonwealth v. Saferian, supra. In this case we need not consider the alleged deficiency in the behavior of counsel, but may proceed directly to the second step of the inquiry.

11981–1981

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 278, § 33E (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

TX 253 (1984–2026) CA 185 (1964–2026) OH 96 (1984–2025) IL 95 (1984–2026) IN 76 (1989–2025) IA 58 (1988–2026) MO 53 (1988–2019) OR 44 (1985–2026) KS 43 (1994–2026) WI 34 (1988–2026) NM 33 (1993–2026) WA 31 (1995–2025) PA 25 (1981–2026) NJ 24 (1983–2026) GA 23 (1985–2026) TN 23 (2001–2020) RI 21 (1983–2021) MI 20 (1975–2026) CT 20 (1985–2023) ID 20 (1993–2026) MN 18 (1988–2026) NY 17 (1988–2025) NC 15 (1986–2022) LA 14 (1991–2017) FL 14 (1999–2021) CO 14 (1989–2025) NV 11 (2012–2024) DE 11 (1983–2026) KY 11 (2010–2025) DC 11 (1984–2026) ME 11 (1981–2025) SC 10 (1990–2017) MD 9 (1993–2025) NE 9 (2015–2019) MS 9 (2007–2024) UT 9 (1991–2026) VT 8 (1990–2025) NH 8 (1985–2021) AR 7 (2018–2025) MA 7 (1981–2024) WY 7 (2005–2025) AK 5 (2019–2025) WV 5 (1989–2017) SD 4 (1985–2018) ND 4 (2002–2016) MT 4 (2003–2025) AL 4 (1994–2016) VI 4 (2012–2024) VA 4 (1992–2025) HI 3 (2002–2015) OK 2 (1991–2011)

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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