Commonwealth v. Snyder

5 Citing cases

  1. Commonwealth v. Duquette

    386 Mass. 834 (Mass. 1982)   Cited 97 times
    In Duquette, the Massachusetts Supreme Court suggested various procedures to be followed when accepting a defendant's admission to sufficient facts to warrant a finding of guilty.

    When the defendant admitted to sufficient facts in the jury of six session, the second judge clearly could have chosen to treat the admission as a plea of guilty. See Commonwealth v. Snyder, 12 Mass. App. Ct. 960 (1981); K.B. Smith, Criminal Practice and Procedure § 728 (1970). It is well-established, however, that a guilty plea may not be accepted without an affirmative showing that the defendant acts voluntarily and understands the consequences of his plea.

  2. Commonwealth v. Bell

    75 N.E.3d 1148 (Mass. App. Ct. 2017)

    First, he argues that the motion and trial judges abused their discretion in denying his motions to sever the charges related to victim 3 from the charges related to victims 1 and 2. Prior to trial, the defendant pleaded guilty to the charges relating to victim 3. A guilty plea effectively "waives all but jurisdictional defects." Commonwealth v. Rodriguez , 17 Mass. App. Ct. 547, 556 (1984), quoting from Commonwealth v. Snyder , 12 Mass. App. Ct. 960 (1981). As such, that argument is waived.

  3. Glenn v. Com

    48 Va. App. 556 (Va. Ct. App. 2006)   Cited 7 times
    Holding that, as owner of the residence, the grandfather had actual authority to consent to a search of the defendant's bedroom; because there was no evidence that grandfather lacked authority to enter defendant's room and because defendant's bedroom did not have a lock or anything restricting access to the room, the court found that the grandfather shared common authority over the bedroom

    . Reid, 420 Mich. 326, 362 N.W.2d 655 (1984); Mont. Code Ann. § 46-12-204(3); Nev.Rev.Stat. § 174.035(3); N.J.R. 3:9-3(f); State v. Hodge, 118 N.M. 410, 882 P.2d 1 (N.M. 1994); N.Y.Crim. P. Law § 710.70; N.C. Gen.Stat. § 15A-979(b); N.D. R.Crim. P. 11(a)(2); Ore.Rev.Stat. 135.335(3); Tenn. R.Crim. P. 37(b)(2)(i); Tex. Code Crim. Proc. art. 44.02 Tex.R.App. P. 25.2(a)(2); Utah R.Crim. P. 11(i); Vt. R.Crim. P. 11(a)(2); W. Va. R.Crim. P. 11(a)(2); Wis. Stat. Ann. § 971.31(10); Wyo. R.Crim. P. 11(a)(2); see also Fed.R.Crim.P. 11(a)(2). For jurisdictions that have expressly declined to adopt a conditional plea practice in the absence of an applicable statute or rule, see State v. Arnsberg, 27 Ariz.App. 205, 553 P.2d 238, 240 (Ariz.Ct.App. 1976); Hooten v. State, 212 Ga.App. 770, 442 S.E.2d 836 (1994); People v. Gonzalez, 313 Ill.App.3d 607, 246 Ill.Dec. 509, 730 N.E.2d 534, 545 (2000); State v. Tobin, 333 N.W.2d 842, 844-45 (Iowa 1983); Bruno v. State, 332 Md. 673, 632 A.2d 1192 (1993); Commonwealth v. Snyder, 12 Mass.App.Ct. 960, 427 N.E.2d 500 (Mass. 1981); State v. Lothenbach, 296 N.W.2d 854, 857-58 (Minn. 1980); State v. Parkhurst, 121 N.H. 821, 435 A.2d 522 (1981); Tabor v. Maxwell, 175 Ohio St. 373, 194 N.E.2d 856 (Ohio 1963); Commonwealth v. Bartley, 8 Pa. D C 4th 605, 609 (1991); State v. Soares, 633 A.2d 1356, 1356 (R.I. 1993); State v. Downs, 361 S.C. 141, 604 S.E.2d 377 (S.C. 2004); see also Lineberry v. State, 747 N.E.2d 1151 (Ind.Ct.App. 2001) (vacating a guilty plea entered after the prosecutor and the trial court erroneously assured the defendant that he could appeal the denial of his pretrial motion to suppress, reasoning that those assurances made the guilty plea involuntary).

  4. Commonwealth v. Nydam

    21 Mass. App. Ct. 66 (Mass. App. Ct. 1985)   Cited 4 times

    See Commonwealth v. Stevens, 379 Mass. 772, 776 (1980). In particular, the judge failed to explain to the defendant that he (the judge) would be entitled to treat admissions of sufficient facts as the functional equivalents of pleas of guilty ( Commonwealth v. Duquette, 386 Mass. at 841; Commonwealth v. Snyder, 12 Mass. App. Ct. 960) and that if he should decide to find the defendant guilty (as he subsequently did), the defendant would be precluded from appellate review of any pretrial rulings (such as those in this case) which did not go to the jurisdiction of the court. Garvin v. Commonwealth, 351 Mass. 661, 663, appeal dismissed and cert. denied, 389 U.S. 13 (1967).

  5. Commonwealth v. Rodriguez

    17 Mass. App. Ct. 547 (Mass. App. Ct. 1984)   Cited 14 times

    "Under the decided cases a guilty plea waives all but jurisdictional defects." Commonwealth v. Snyder, 12 Mass. App. Ct. 960 (1981). See Commonwealth v. Zion, 359 Mass. 559, 563 (1971).