Commonwealth v. Leonardi
Massachusetts Appeals Court
1Opinion of the CourtWolohojian, J.
The defendant, proceeding pro se (with standby counsel) and without a jury, was convicted of assault and battery, G. L. c. 265, § 13A, in the Boston Municipal Court. On appeal, he challenges the validity of his jury and counsel waivers. We reverse, holding that the defendant’s jury waiver was invalid because the requirements of G. L. c. 218, § 26A, were not satisfied.
*2721. Background. On January 28, 2008, the defendant appeared before three different judges in three separate events pertaining to this case.
At the first appearance, the defendant (through counsel) informed the judge of his desire to…
2Cases cited11 opinions
- Sullivan v. Town of BrooklineMassachusetts Supreme Judicial Court · 2001
- Ciummei v. CommonwealthMassachusetts Supreme Judicial Court · 1979
- Commissioner of Correction v. Superior Court Department of the Trial CourtMassachusetts Supreme Judicial Court · 2006
- Commonwealth v. MeansMassachusetts Supreme Judicial Court · 2009
- Commonwealth v. ConefreyMassachusetts Supreme Judicial Court · 1991
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3Cited by2 opinions
- Commonwealth v. ClemensMassachusetts Appeals Court · 2010
- Commonwealth v. HempelMassachusetts Appeals Court · 2026