1 Md. App. 455 - Gaudio v. State’s Empirical Analysis
1967
Citation profile
90 state decisions
How this case has been cited
Cited by 92 later decisions — most recently July 1987 · most notably People v. Rodney P.(Anonymous) (1967), State v. Kidd (1977)
90 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Miranda v. State of Arizona Vignera · Mapp v. Ohio · Johnson v. State of New Jersey · Henry v. State of Mississippi · JOHNSON, ETC. v. State
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 92 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"The vice of the custodial interrogation * * * [lies] in the psychological coercion implicit in interrogation in the isolated chamber from which the suspect may reasonably believe he cannot leave. In such circumstances the person detained or arrested finds himself completely and suddenly cut off from freedom of movement. An involuntary immobilization by law enforcement officers dramatizes the fact that the individual stands suspected or accused of crime. Lacking knowledge of his constitutional rights, he may feel that he can extricate himself from the situation only by submitting to interrogation. He may reasonably believe that if he attempts to leave the interrogation chamber the authorities will impose immediate detention. * * * Although in this pre- Miranda case we are not constitutionally compelled to accept Miranda standards, we find the above reasoning entirely persuasive in defining custody as that term is used in Escobedo and Dorado . Accordingly, we adopt the definition of the United States Supreme Court of in-custody interrogation: `By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.' * * * We hold that custody occurs if the suspect is physically deprived of his freedom of action in any significant way or is led to believe, as a reasonable person, that he is so deprived."”
1 later decision quote this exact passage · from the majority““ ‘An individual swept from familiar surroundings into police custody, surrounded by antagonistic forces, and subjected to the techniques of persuasion described above cannot be otherwise than under compulsion to speak. As a practical matter, the compulsion to speak in the isolated setting of the police station may well be greater than in the courts or other official investigations, where there are often impartial observers to guard against intimidation or trickery.’ ””
1 later decision quote this exact passage · from the majority“We recognize the rationale of Miranda and share the concern for justice — the constant and perpetual disposition to render every man, whether innocent or guilty, what is his due. But a balance must be maintained which does justice not only to the accused but also to society. When weighted too much on either side, imbalance occurs and justice is not served. [Id. at 469.]”
1 later decision quote this exact passage · from the majoritye.g. Vines v. State
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.