Massachusetts General Laws

Mass. Gen. Laws ch. 233, § 22 (2026)

Cross-examination of adverse party; corporation's agent as adverse party

✓ current as of July 2026

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Section 22. A party who calls the adverse party as a witness shall be allowed to cross-examine him. In case the adverse party is a corporation, an officer or agent thereof, so called as a witness, shall be deemed such an adverse party for the purposes of this section.

Notes of Decisions

Cited in 14 cases, 1925–2003 · leading case: Commonwealth v. Canon, 368 N.E.2d 1181 (Mass. 1977).

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Commonwealth v. Canon, 368 N.E.2d 1181 (Mass. 1977). · cites it 4× “G.L.c. 233, § 22. The substantial question is whether the defendant then had an adequate motive for the testing on cross-examination of the credibility of Curley's testimony.”

Productora E Importadora De Papel v. Fleming, 383 N.E.2d 1129 (Mass. 1978). “Provided that counsel did not belabor his questions, he should have been permitted to ask his questions then instead of waiting to call the witness pursuant to G. L. c. 233, § 22. (b) Fleming’s counsel called Loring Saltus, a local newsprint broker who had about five years’…”

Guinan v. Famous Players-Lasky Corp., 167 N.E. 235 (Mass. 1929). “*523 The plaintiff called as a witness one Bowditch, a defendant in one of the cases tried with this case, and was allowed to cross-examine him.”

Civitarese v. Gorney, 266 N.E.2d 668 (Mass. 1971). · cites it 2× “He was being cross-examined under the provisions of G. L. c. 233, § 22, when the follow *657 ing occurred: 1 Q.”

Phillips v. Vorenberg, 156 N.E. 61 (Mass. 1927). “By G. L. c. 233, § 22, a party who calls the adverse party as a witness shall be allowed to cross-examine him; but when the defendant was called as a witness by his counsel, the trial judge ruled, that his counsel could not cross-examine him except as to the evidence given by…”

Goldman v. Ashkins, 266 Mass. 374 (Mass. 1929). “Whatever facts are material to the issues raised may be developed by interrogatories under our statute. The ascertainment of facts having probative force on the issues, nothing more and nothing less, is the whole object of a trial in court.”

Labrie v. Midwood, 174 N.E. 214 (Mass. 1931). “233, § 22, and at its conclusion the plaintiff, subject to the exception of the defendant, was permitted to introduce a record of the conviction in the Superior Court of the defendant of the crime of adultery with the plaintiff’s wife committed on May 18, 1927.”

Walsh v. Feinstein, 146 N.E. 355 (Mass. 1925). “” Subject to the exception of the defendant, Samuels was then asked, “ What did you say to him when he told you that? ” and replied thereto “ I asked him if the girl had been badly hurt and he said, ‘ No, he didn’t think so.”

Dindio v. Meshaka, 175 N.E. 170 (Mass. 1931). “(G. L. c. 233, § 22.) He testified that he was the person for whom the plaintiff performed labor as alleged in his declaration.”

Marrone v. Rand-Whitney Corp., 234 N.E.2d 294 (Mass. 1968). “The defendant’s comptroller was called as a witness by the plaintiff (G. L. c. 233, § 22) and testified, over the defendant’s objection, that he instructed Miller as to what route to follow, and that he could have told Miller how to drive his car en route.”

Adoption of Salvatore, 786 N.E.2d 858 (Mass. App. Ct. 2003). “Not only did he not object when counsel for DSS indicated he intended to call them — nor did he object when the parents were in fact called to the stand at trial — but his counsel, when asked whether he had any witnesses, answered, “Just my client, your Honor.”

Nuger v. Robinson, 591 N.E.2d 1116 (Mass. App. Ct. 1992). “Although it is true that a trial judge has broad discretion to keep cross-examination within reasonable bounds, the grounds for the judge’s exclusions here were G. L. c. 233, § 22, and Proposed Mass.R.Evid.”

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