114 Md. App. 480 - Bell v. State’s Empirical Analysis
1997
Citation profile
15 state decisions
How this case has been cited
Cited by 15 later decisions — most recently May 2012
15 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 Bruton v. United States · Ohio v. Roberts · Berger v. United States · Chambers v. Mississippi · Pointer v. Texas
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Additionally, prior inconsistent statements of the witness may be examined with a view towards challenging the witness’s veracity. Maryland Rules 5-613; 5-616. Moreover, Maryland Rule 5-616 permits, inter alia, impeachment by questioning of the witness directed toward “proving that the facts are not as testified to by the witness” or by showing bias, prejudice, motive to testify falsely, or lack of knowledge. In appropriate circumstances, extrinsic evidence may also be introduced to impeach the witness’s credibility. Maryland Rule 5-616(b). “Evidence proved through another witness ... is extrinsic evidence. The admissibility of extrinsic evidence which is offered for substantive purposes is governed by all the usual rules of evidence: no special rule applies when the evidence has the incidental effect of discrediting a witness’ testimony.” McLain, supra, § 607.4, at 50. Yet the State has not referred us to any authority to support its claim that it was entitled to impeach the defendant with the hearsay statement of a material eyewitness who was not present at trial, whose unavailability was not established, and whose oral statement was neither tested in another proceeding, proffered as a sworn statement, nor adopted by the declarant.”
1 later decision quote this exact passage“Statements that are otherwise inadmissible are not salvaged by invoking the mantra of “impeachment.” If the State could not properly use the statement under the applicable rules of evidence, we fail to see how it could, instead, read the statement to the jury, apparently line by line, through the questions it posed to the defendant. Unquestionably, a party may attempt to impeach a witness by challenging his or her credibility.... But impeachment must be consistent with the common law and the rules of evidence.”
1 later decision quote this exact passagee.g. Sweetney 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.