Massiah violation (Tennessee) · Go Syfert
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Massiah violation in Tennessee

6 Tennessee opinions name it 2 courts 1980–2015 0 in the last five years

The cases below were cited by Tennessee 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 (6)

CaseFollowedCited
State v. Mitchellgreen
tenn · 1980 · cited in 2 Tennessee opinions naming this issue, 1997–1997
2 sentences

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

22
Willis Randolph v. People of the State of California Attorney General of the State of California James Hamlet, Wardengreen
ca9 · 2004 · cited in 1 Tennessee opinions naming this issue, 2015–2015
2 sentences

2015The Sixth Circuit reasoned: As Henry illustrates, a Massiah violation can occur even where the State specifically instructs its informant “not to initiate any conversation with or question [a defendant] regarding the [offense for which he had been indicted].” Henry, 447 U.S. at 266 (emphasis added). “[I]t is not the government’s intent or overt acts that are important; rather, it is the ‘likely . . . result’ of the government’s acts.” Randolph v. California, 380 F.3d 1133, 1144 (9th Cir. 2004) (quoting Henry, 447 U.S. at 271 ).

2015The Sixth Circuit reasoned: As Henry illustrates, a Massiah violation can occur even where the State specifically instructs its informant “not to initiate any conversation with or question [a defendant] regarding the [offense for which he had been indicted].” Henry, 447 U.S. at 266 (emphasis added). “[I]t is not the government’s intent or overt acts that are important; rather, it is the ‘likely . . . result’ of the government’s acts.” Randolph v. California, 380 F.3d 1133, 1144 (9th Cir. 2004) (quoting Henry, 447 U.S. at 271 ).

11
United States v. Henrygreen
scotus · 1980 · cited in 1 Tennessee opinions naming this issue, 2015–2015
2 sentences

2015The Sixth Circuit reasoned: As Henry illustrates, a Massiah violation can occur even where the State specifically instructs its informant “not to initiate any conversation with or question [a defendant] regarding the [offense for which he had been indicted].” Henry, 447 U.S. at 266 (emphasis added). “[I]t is not the government’s intent or overt acts that are important; rather, it is the ‘likely . . . result’ of the government’s acts.” Randolph v. California, 380 F.3d 1133, 1144 (9th Cir. 2004) (quoting Henry, 447 U.S. at 271 ).

2015The Sixth Circuit reasoned: As Henry illustrates, a Massiah violation can occur even where the State specifically instructs its informant “not to initiate any conversation with or question [a defendant] regarding the [offense for which he had been indicted].” Henry, 447 U.S. at 266 (emphasis added). “[I]t is not the government’s intent or overt acts that are important; rather, it is the ‘likely . . . result’ of the government’s acts.” Randolph v. California, 380 F.3d 1133, 1144 (9th Cir. 2004) (quoting Henry, 447 U.S. at 271 ).

11
State v. Sawyergreen
tenn · 2005 · cited in 1 Tennessee opinions naming this issue, 2011–2011
2 sentences

2011Interrogation “refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.” State v. Sawyer, 156 S.W.3d 531, 534 (Tenn. 2005) (quoting Rhode Island v. Innis, 446 U.S. 291, 301 (1980)).

2011Interrogation “refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.” State v. Sawyer, 156 S.W.3d 531, 534 (Tenn. 2005) (quoting Rhode Island v. Innis, 446 U.S. 291, 301 (1980)).

11
Rhode Island v. Innisgreen
scotus · 1980 · cited in 1 Tennessee opinions naming this issue, 2011–2011
2 sentences

2011Interrogation “refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.” State v. Sawyer, 156 S.W.3d 531, 534 (Tenn. 2005) (quoting Rhode Island v. Innis, 446 U.S. 291, 301 (1980)).

2011Interrogation “refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.” State v. Sawyer, 156 S.W.3d 531, 534 (Tenn. 2005) (quoting Rhode Island v. Innis, 446 U.S. 291, 301 (1980)).

11
State v. Bushgreen
tenn · 1997 · cited in 1 Tennessee opinions naming this issue, 2007–2007
2 sentences

2007State v. Bush, 942 S.W.2d 489, 513 (Tenn. 1997).

2007State v. Bush, 942 S.W.2d 489, 513 (Tenn. 1997).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Hudson v. Maryland green
scotus · 1980
2 sentences

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

21997–1997
Brown v. Mitchell green
scotus · 1980
2 sentences

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

21997–1997
Annicaro v. Florida green
scotus · 1980
2 sentences

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

1997The initiation of adversary proceedings is “marked by formal charge, which [has been] construe[d] to be an arrest warrant, or at the time of the preliminary hearing in those rare cases where a preliminary hearing is not preceded by an arrest warrant, or by indictment or presentment.” State v. Mitchell, 593 S.W.2d 280, 286 (Tenn.1980), cert. denied, 449 U.S. 845 , 101 S.Ct. 128 , 66 L.Ed.2d 53 (1980).

11997–1997
Miller v. California green
scotus · 1968
2 sentences

1980The case of Miller v. California, 392 U.S. 616 , 88 S.Ct. 2258 , 20 L.Ed.2d 1332 (1968), was decided per curiam.

1980The case of Miller v. California, 392 U.S. 616 , 88 S.Ct. 2258 , 20 L.Ed.2d 1332 (1968), was decided per curiam.

11980–1980
Parker L. Hancock, Warden, New Hampshire State Prison v. Charles White green
ca1 · 1967
2 sentences

1980The Court applied the Massiah rule, holding that: [T]he Massiah rule is not limited to Massi-ah “circumstances” but applies to exclude post-indictment incriminating statements of an accused to government agents in the absence of counsel even when not deliberately elicited by interrogation or induced by misapprehension engendered by trickery or deception. 378 F.2d at 482 .

1980The Court applied the Massiah rule, holding that: [T]he Massiah rule is not limited to Massi-ah “circumstances” but applies to exclude post-indictment incriminating statements of an accused to government agents in the absence of counsel even when not deliberately elicited by interrogation or induced by misapprehension engendered by trickery or deception. 378 F.2d at 482 .

11980–1980

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 39-13-202 (4) TN § Tenn. Code Ann. § 39-13-204 (3) TN § Tenn. Code Ann. § 39-13-206 (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

CA 43 (1977–2023) NY 9 (1966–2010) ID 9 (1981–2024) IL 8 (1967–2023) TX 6 (1969–2021) TN 6 (1980–2015) FL 6 (1991–2026) MA 4 (1971–2007) CT 4 (1972–2025) MD 4 (1966–1978) IA 3 (2015–2016) WI 2 (2010–2022) MI 2 (1983–1985)

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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