Hoffman factors (Maryland) · Go Syfert
← Maryland issues

Hoffman factors in Maryland

6 Maryland opinions name it 2 courts 2005–2022 2 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 (10)

CaseFollowedCited
McDermott v. Doughertygreen
md · 2005 · cited in 2 Maryland opinions naming this issue, 2005–2017
2 sentences

2017See id.; see also McDermott, 385 Md. at 419 , 869 A.2d at 809 (referencing the Hoffman factors as the “standards and guidelines that generate ‘exceptional circumstances[.]’ ”).

2017See id.; see also McDermott, 385 Md. at 419 , 869 A.2d at 809 (referencing the Hoffman factors as the “standards and guidelines that generate ‘exceptional circumstances[.]’ ”).

22
Burak v. Burakgreen
md · 2017 · cited in 2 Maryland opinions naming this issue, 2021–2022
2 sentences

2022While this first factor is “not the exclusive consideration,” a “court must first determine that the child at issue has spent a long period of time away from his or her biological parent before considering the other Hoffman factors.” Id. at 662-63 .

2022While this first factor is “not the exclusive consideration,” a “court must first determine that the child at issue has spent a long period of time away from his or her biological parent before considering the other Hoffman factors.” Id. at 662-63 .

12
Sider v. Sidergreen
md · 1994 · cited in 2 Maryland opinions naming this issue, 2005–2017
2 sentences

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

12
Ross v. Hoffmangreen
md · 1977 · cited in 1 Maryland opinions naming this issue, 2017–2017
2 sentences

2017Although the Hoffman factors serve merely “as a guide” to aid a court in determining whether exceptional circumstances exist, see Hoffman, 280 Md. at 188 , 372 A.2d at 592 , we note that the Hoffman factors served as the analytical framework that the hearing judge relied on in ultimately finding that exceptional circumstances existed. 58 Accordingly, although we have previously acknowledged the existence of other factors that may be relevant in an exceptional circumstances inquiry, 59 we will confine our review of the hearing judge’s exceptional circumstances finding to his application of the

2017Although the Hoffman factors serve merely “as a guide” to aid a court in determining whether exceptional circumstances exist, see Hoffman, 280 Md. at 188 , 372 A.2d at 592 , we note that the Hoffman factors served as the analytical framework that the hearing judge relied on in ultimately finding that exceptional circumstances existed. 58 Accordingly, although we have previously acknowledged the existence of other factors that may be relevant in an exceptional circumstances inquiry, 59 we will confine our review of the hearing judge’s exceptional circumstances finding to his application of the

11
Piotrowski v. State Ex Rel. Kowalekgreen
md · 1941 · cited in 1 Maryland opinions naming this issue, 2017–2017
2 sentences

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

11
Turner v. Whistedgreen
md · 1992 · cited in 1 Maryland opinions naming this issue, 2017–2017
2 sentences

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

11
Monroe v. Monroegreen
md · 1993 · cited in 1 Maryland opinions naming this issue, 2017–2017
2 sentences

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

2017See Sider v. Sider, 334 Md. 512, 532 , 639 A.2d 1076, 1086 (1994) (quoting Turner v. Whisted, 327 Md. 106, 116-17 , 607 A.2d 935, 940 (1992)); see also Monroe v. Monroe, 329 Md. 758, 775-76 , 621 A.2d 898, 906 (1993) (concluding that the child’s relationship with a third-party is a relevant factor in exceptional circumstances inquiry). 60 See Piotrowski v. State, 179 Md. 377, 378-79, 383 , 18 A.2d 199, 199, 201-02 (continued . . .) 96 “exceptional circumstances” test and the Hoffman factors relate only to situations where a parent has not retained continuous custody of the child, the hearing j

11
Bhagwat v. Stategreen
md · 1995 · cited in 1 Maryland opinions naming this issue, 2010–2010
2 sentences

2010We have framed the Hoffman standard as a two-part inquiry: "(1) whether there is a reasonable basis for the invocation of the privilege; and (2) whether the privilege is invoked in good faith[.]" Simmons, 392 Md. at 298 , 896 A.2d at 1034 (quoting Bhagwat v. State, 338 Md. 263, 272-73 , 658 A.2d 244, 248 (1995)).

2010We have framed the Hoffman standard as a two-part inquiry: "(1) whether there is a reasonable basis for the invocation of the privilege; and (2) whether the privilege is invoked in good faith[.]" Simmons, 392 Md. at 298 , 896 A.2d at 1034 (quoting Bhagwat v. State, 338 Md. 263, 272-73 , 658 A.2d 244, 248 (1995)).

11
Choi v. Stategreen
md · 1989 · cited in 1 Maryland opinions naming this issue, 2010–2010
2 sentences

2010Ultimately, though, the Fifth Amendment privilege "must be accorded liberal construction." Hoffman, 341 U.S. at 486 , 71 S.Ct. 814 ; see also Choi v. State, 316 Md. 529, 536 , 560 A.2d 1108, 1111 (1989) ("This Court has repeatedly emphasized that the privilege against compelled self-incrimination, under both the Fifth Amendment and Art. 22 of the Declaration of Rights, must be accorded a liberal construction in favor of the right that it was intended to secure." (Internal quotation marks and citations omitted)).

2010Ultimately, though, the Fifth Amendment privilege "must be accorded liberal construction." Hoffman, 341 U.S. at 486 , 71 S.Ct. 814 ; see also Choi v. State, 316 Md. 529, 536 , 560 A.2d 1108, 1111 (1989) ("This Court has repeatedly emphasized that the privilege against compelled self-incrimination, under both the Fifth Amendment and Art. 22 of the Declaration of Rights, must be accorded a liberal construction in favor of the right that it was intended to secure." (Internal quotation marks and citations omitted)).

11
Richardson v. Stategreen
md · 1979 · cited in 1 Maryland opinions naming this issue, 2009–2009
2 sentences

2009See also Richardson v. State, 285 Md. 261, 267 , 401 A.2d 1021 (1979) (“[The] continued vitality [of the Hoffman standard] has been recognized both by the Supreme Court of the United States, and the courts of this State.” (citations omitted)).

2009See also Richardson v. State, 285 Md. 261, 267 , 401 A.2d 1021 (1979) (“[The] continued vitality [of the Hoffman standard] has been recognized both by the Supreme Court of the United States, and the courts of this State.” (citations omitted)).

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 (2)

CaseCitedYears
Hoffman v. United States green
scotus · 1951
2 sentences

2009The Court of *507 Appeals has noted its consistent adherence to this standard, which it derived from Hoffman, supra: We have consistently applied the [Hoffman standard], that a witness is entitled to invoke the privilege against self-incrimination if “the witness has reasonable cause to apprehend danger from a direct answer” and that “[t]o sustain the privilege, it need only be evident from the implications of the question, in the setting in which it is asked, that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure

2009The Court of *507 Appeals has noted its consistent adherence to this standard, which it derived from Hoffman, supra: We have consistently applied the [Hoffman standard], that a witness is entitled to invoke the privilege against self-incrimination if “the witness has reasonable cause to apprehend danger from a direct answer” and that “[t]o sustain the privilege, it need only be evident from the implications of the question, in the setting in which it is asked, that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure

22009–2010
Simmons v. State green
md · 2006
2 sentences

2010We have framed the Hoffman standard as a two-part inquiry: "(1) whether there is a reasonable basis for the invocation of the privilege; and (2) whether the privilege is invoked in good faith[.]" Simmons, 392 Md. at 298 , 896 A.2d at 1034 (quoting Bhagwat v. State, 338 Md. 263, 272-73 , 658 A.2d 244, 248 (1995)).

2010We have framed the Hoffman standard as a two-part inquiry: "(1) whether there is a reasonable basis for the invocation of the privilege; and (2) whether the privilege is invoked in good faith[.]" Simmons, 392 Md. at 298 , 896 A.2d at 1034 (quoting Bhagwat v. State, 338 Md. 263, 272-73 , 658 A.2d 244, 248 (1995)).

12010–2010

Where else courts name it

MS 14 (1990–2019) CA 8 (1895–2021) FL 7 (1974–2022) ID 6 (1988–2024) MD 6 (2005–2022) PA 6 (1975–2024) TX 5 (1994–2019) IN 5 (2003–2017) NY 5 (1908–2019) WA 4 (1987–2021) IL 4 (1982–2011) UT 2 (1984–2003) WI 2 (2022–2025) VA 2 (1979–2001) AK 2 (2001–2022) OR 2 (2025–2025)

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.

← Caselaw search · G Cite Topics · Brief Check