stage analysis (Michigan) · Go Syfert
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stage analysis in Michigan

7 Michigan opinions name it 2 courts 1999–2024 3 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 (2)

CaseFollowedCited
Town v. Michigan Bell Telephone Co.red
mich · 1997 · cited in 2 Michigan opinions naming this issue, 2002–2003
2 sentences

2003Town, supra at 696-697, 707 , 568 N.W.2d 64 .

2002Town, supra at 696-697, 707 .

12
People of Michigan v. Kainte Deshawn Hickeygreen
mich · 2019 · cited in 1 Michigan opinions naming this issue, 2021–2021
2 sentences

2021See e.g., People v Hickey, 504 Mich 975 ; 933 NW2d 311 (2019); People v Sheena, 497 Mich 1021 ; 862 NW2d 648 (2015). 12 In its July 23, 2019 opinion, the Supreme Court noted that “[w]hether suppression of evidence under the exclusionary rule is appropriate is an issue separate from whether defendant’s Fourth Amendment rights where violated by police conduct.” [Hammerlund, 504 Mich at 463 (emphasis added)].

2021See e.g., People v Hickey, 504 Mich 975 ; 933 NW2d 311 (2019); People v Sheena, 497 Mich 1021 ; 862 NW2d 648 (2015). 12 In its July 23, 2019 opinion, the Supreme Court noted that “[w]hether suppression of evidence under the exclusionary rule is appropriate is an issue separate from whether defendant’s Fourth Amendment rights where violated by police conduct.” [Hammerlund, 504 Mich at 463 (emphasis added)].

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 (5)

CaseCitedYears
Brady v. Maryland green
scotus · 1963
2 sentences

2024In Minsky, the trial court held an ex parte meeting with the prosecution to decide whether the prosecution had to disclose to the defense a certain report containing potential impeachment evidence at a stage where the defense was arguing that the report was “subject to disclosure under the Jencks Act and Brady [v Maryland, 373 US 83 ; 83 S Ct 1194 ; 10 L Ed 2d 215 (1963),]” and the release of the report would have allowed the defense to undermine the credibility of a key government witness.

2024In Minsky, the trial court held an ex parte meeting with the prosecution to decide whether the prosecution had to disclose to the defense a certain report containing potential impeachment evidence at a stage where the defense was arguing that the report was “subject to disclosure under the Jencks Act and Brady [v Maryland, 373 US 83 ; 83 S Ct 1194 ; 10 L Ed 2d 215 (1963),]” and the release of the report would have allowed the defense to undermine the credibility of a key government witness.

12024–2024
Roeur Van v. Kurt Jones, Warden green
ca6 · 2007
1 sentence

2024In Van v Jones, 475 F3d 292 (CA 6 2007), the Sixth Circuit Court of Appeals lamented the lack of a “comprehensive and final one-line definition of ‘critical stage,’ ” but stated “the Supreme Court and our court have offered six short definitional statements over time: 1) A critical stage presents a moment when “[a]vailable defenses may be irretrievably lost, if not then and there asserted.” 1 As stated by the Court in King, 512 Mich at 15-16: Lewis is categorically different from the instant case.

12024–2024
Duncan v. State green
michctapp · 2009
2 sentences

2024The critical stage analysis “applies to preliminary proceedings where rights may be sacrificed or defenses lost.” Duncan v Michigan, 284 Mich App 246, 263-264 ; 774 NW2d 89 (2009) (quotation marks and citations omitted).

2024The critical stage analysis “applies to preliminary proceedings where rights may be sacrificed or defenses lost.” Duncan v Michigan, 284 Mich App 246, 263-264 ; 774 NW2d 89 (2009) (quotation marks and citations omitted).

12024–2024
Purkett v. Elem green
scotus · 1995
1 sentence

2014Purkett, 514 US at 768 .

12014–2014
Greenlees v. Owen Ames Kimball Co. green
mich · 1954
2 sentences

1999This careful approach can be seen in Greenlees v Owen Ames Kimball Co, 340 Mich 670, 676 ; 66 NW2d 227 (1954), where this Court, in setting the stage for its analysis of our third-party beneficiary statute, quoted with approval 12 Am Jur, Contracts, § 282, p 834: “The principle that one not a party or privy to a contract but who is the beneficiary thereof is entitled to maintain an action for its breach is not so far extended as to give to a third person who is only indirectly and incidentally benefited by the contract the right to sue upon it.

1999This careful approach can be seen in Greenlees v Owen Ames Kimball Co, 340 Mich 670, 676 ; 66 NW2d 227 (1954), where this Court, in setting the stage for its analysis of our third-party beneficiary statute, quoted with approval 12 Am Jur, Contracts, § 282, p 834: “The principle that one not a party or privy to a contract but who is the beneficiary thereof is entitled to maintain an action for its breach is not so far extended as to give to a third person who is only indirectly and incidentally benefited by the contract the right to sue upon it.

11999–1999

Where else courts name it

CA 67 (1967–2026) IL 22 (1935–2026) TX 16 (1970–2023) MA 15 (1982–2025) OH 13 (2000–2026) NY 12 (1878–2024) MD 9 (1971–2023) OR 8 (1986–2025) WI 7 (1971–2016) PA 7 (1974–2025) MI 7 (1999–2024) NE 7 (2000–2022) NC 6 (1974–2022) TN 6 (2008–2020) WY 6 (1987–2022) FL 6 (1977–2022) WA 5 (1971–2017) IA 5 (1970–2022) CT 5 (1968–2011) VT 5 (1982–2026) NJ 5 (1951–2020) LA 5 (1985–2026) UT 4 (2002–2025) HI 4 (1995–2026) MO 4 (2016–2023) IN 4 (1975–1993) VA 4 (2007–2024) ID 3 (2009–2015) KY 3 (1971–2011) NH 3 (2007–2012) KS 3 (1984–2016) CO 3 (2010–2025) DE 3 (2015–2018) WV 3 (1993–2023) MN 3 (1983–2008) MT 3 (1959–2003) GA 3 (1908–2013) DC 2 (1981–2008) AL 2 (1981–1984) AZ 2 (2014–2026)

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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