voluntary and intelligent waiver (Virginia) · Go Syfert
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voluntary and intelligent waiver in Virginia

6 Virginia opinions name it 2 courts 1991–2010 0 in the last five years

The cases below were cited by Virginia 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 (3)

CaseFollowedCited
Commonwealth v. Williamsgreen
va · 2001 · cited in 2 Virginia opinions naming this issue, 2003–2010
2 sentences

2010The trial court denied Cokes' motion. "[O]nce a defendant makes a voluntary and intelligent waiver of [his right to a jury trial], his request to withdraw that waiver and be tried by a jury is subject to the circuit court's discretion." Commonwealth v. Williams, 262 Va. 661, 670 , 553 S.E.2d 760, 764 (2001).

2010The trial court denied Cokes' motion. "[O]nce a defendant makes a voluntary and intelligent waiver of [his right to a jury trial], his request to withdraw that waiver and be tried by a jury is subject to the circuit court's discretion." Commonwealth v. Williams, 262 Va. 661, 670 , 553 S.E.2d 760, 764 (2001).

22
Sisk v. Commonwealthgreen
vactapp · 1986 · cited in 2 Virginia opinions naming this issue, 1991–1997
2 sentences

1997Sisk, 3 Va.App. at 465 , 350 S.E.2d at 680 . [7] The Hunter decision did not "limit the manner in which the trial court may determine that the appellant has made a knowing and intelligent waiver of the right to be present at trial," 13 Va.App. at 193 , 409 S.E.2d at 486 , and it specifically did not determine the circumstances under which the execution of a bond form would be sufficient to show a voluntary and intelligent waiver.

1997Sisk, 3 Va.App. at 465 , 350 S.E.2d at 680 . [7] The Hunter decision did not "limit the manner in which the trial court may determine that the appellant has made a knowing and intelligent waiver of the right to be present at trial," 13 Va.App. at 193 , 409 S.E.2d at 486 , and it specifically did not determine the circumstances under which the execution of a bond form would be sufficient to show a voluntary and intelligent waiver.

12
Jones v. Commonwealthgreen
vactapp · 1997 · cited in 1 Virginia opinions naming this issue, 2003–2003
2 sentences

2003Id. at 640 , 484 S.E.2d at 620 (emphasis in original). “[O]nce a defendant makes a voluntary and intelligent waiver of this right, his request to withdraw that waiver and be tried by a jury is subject to the [trial] court’s discretion.” Commonwealth v. Williams, 262 Va. 661, 670 , 553 S.E.2d 760, 764 (2001).

2003Id. at 640 , 484 S.E.2d at 620 (emphasis in original). “[O]nce a defendant makes a voluntary and intelligent waiver of this right, his request to withdraw that waiver and be tried by a jury is subject to the [trial] court’s discretion.” Commonwealth v. Williams, 262 Va. 661, 670 , 553 S.E.2d 760, 764 (2001).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Hunter v. Commonwealth green
vactapp · 1991
2 sentences

1997The Hunter decision did not "limit the manner in which the trial court may determine that the appellant has made a knowing and intelligent waiver of the right to be present at trial,” 13 Va.App. at 193 , 409 S.E.2d at 486 , and it specifically did not determine the circumstances under which the execution of a bond form would be sufficient to show a voluntary and intelligent waiver.

1997The Hunter decision did not "limit the manner in which the trial court may determine that the appellant has made a knowing and intelligent waiver of the right to be present at trial,” 13 Va.App. at 193 , 409 S.E.2d at 486 , and it specifically did not determine the circumstances under which the execution of a bond form would be sufficient to show a voluntary and intelligent waiver.

21996–1997
Thomas v. Commonwealth green
va · 1977
1 sentence

2001Id. at 555 , 238 S.E.2d at 835 .

12001–2001
Head v. Commonwealth green
vactapp · 1986
2 sentences

1997Id. at 193 n. 4, 409 S.E.2d at 486 n. 4. [8] Because we find the "Appearance at Trial" form to have provided sufficient notice and warning, we, like the panel in Hunter , do not address what provisions in a bond recognizance form or under what circumstances the execution of such a form would be sufficient to show a voluntary and intelligent waiver. [9] To the extent that our holding here conflicts with our holding in Head, 3 Va.App. at 169-70 , 348 S.E.2d at 428 , regarding prejudice caused by a defendant's failure to appear for trial, we overrule Head . [10] Tortora has been cited as the lead

1997Id. at 193 n. 4, 409 S.E.2d at 486 n. 4. [8] Because we find the "Appearance at Trial" form to have provided sufficient notice and warning, we, like the panel in Hunter , do not address what provisions in a bond recognizance form or under what circumstances the execution of such a form would be sufficient to show a voluntary and intelligent waiver. [9] To the extent that our holding here conflicts with our holding in Head, 3 Va.App. at 169-70 , 348 S.E.2d at 428 , regarding prejudice caused by a defendant's failure to appear for trial, we overrule Head . [10] Tortora has been cited as the lead

11997–1997

Statutes the citing opinions construe

VA § Va. Code Ann. § 19.2-259 (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 37 (1962–2026) NY 31 (1973–2024) FL 16 (1976–2013) NE 16 (1976–2026) AR 15 (1982–2025) TX 12 (1976–2005) IN 9 (1970–2015) DC 8 (1978–2019) MN 7 (1980–2023) VA 6 (1991–2010) OH 6 (1981–2025) MA 6 (1977–2018) IA 6 (1977–2023) IL 6 (1970–2017) CT 5 (1984–2021) LA 5 (2000–2015) GA 5 (1986–2025) MS 4 (1969–2003) NC 4 (1988–2004) WA 3 (1994–2006) SD 3 (1958–2019) MO 3 (1979–1980) NV 3 (1975–1998) NJ 3 (1980–2007) PA 2 (1979–1989) KY 2 (2001–2004) TN 2 (1983–2017) MD 2 (1976–2008) AZ 2 (2007–2017) CO 2 (2000–2006) OR 2 (1985–1996)

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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