Snyder v. Massachusetts

Status

2,813 later cases cite Snyder v. Massachusetts; 238 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Treatments

Overruled in Part

• The Supreme Court rejected Snyder's statement that the Fourteenth Amendment did not protect the Fifth Amendment privilege against self-incrimination from state action.

  Malloy v. Hogan · Supreme Court of the United States · filed June 15, 1964

  In this case we are asked to reconsider prior decisions holding that the privilege against self-incrimination is not safeguarded against state action by the Fourteenth Amendment. Twining v. New Jersey, 211 U. S. 78; Adamson v. California, 332 U. S. 46.1 ... For other statements by the Court that the Fourteenth Amendment does not apply the federal privilege in state proceedings, see Cohen v. Hurley, 366 U. S. 117, 127-129; Snyder v. Massachusetts, 291 U. S. 97, 105.

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• The Supreme Court rejected Snyder's dicta that the right to a jury trial in serious criminal cases was not essential to ordered liberty and could be denied by the states.

  Duncan v. Louisiana · Supreme Court of the United States · filed May 20, 1968

  In neither Palko nor Snyder was jury trial actually at issue, although both cases contain important dicta asserting that the right to jury trial is not essential to ordered liberty and may be dispensed with by the States regardless of the Sixth and Fourteenth Amendments. These observations, though weighty and respectable, are nevertheless dicta, unsupported by holdings in this Court that a State may refuse a defendant’s demand for a jury trial when he is charged with a serious crime. Perhaps because the right to jury trial was not directly at stake, the Court’s remarks about the jury in Palko and Snyder took no note of past or current developments regarding jury trials, did not consider its purposes and functions, attempted no inquiry into how well it was performing its job, and did not discuss possible distinctions between civil and criminal cases. In Malloy v. Hogan, supra, the Court rejected Palko’s discussion of the self-incrimination clause. Respectfully, we reject the prior dicta regarding jury trial in criminal cases.

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Questioned

• The court questioned Snyder's approval of taking a jury view without the defendant present, reasoning that fundamental fairness favors the defendant's direct observation of the proceedings.

  United States v. Lopez · E.D.N.Y. · filed May 14, 1971

  But any defendant, if he is found guilty, should, as a matter of fundamental fairness and as part of the rehabilitative process, have the assurance, by reason of his direct observation, that justice was done. There could hardly be anything more rankling to a defendant and destructive of his morale and incentive to reform than to have the nagging suspicion that something was presented to the Court which should not have been. This factor, among others places in doubt the validity of Snyder v. Massachusetts, 291 U.S. 97, 54 S.Ct. 330, 78 L.Ed. 674 (1934), overruled on other grounds, Malloy v. Hogan, 378 U.S. 1, 84 S.Ct. 1489, 12 L.Ed.2d 653 (1964), in which the Court approved the taking of a view without the defendant being present.

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