13 Md. App. 196 - Mills v. State’s Empirical Analysis
1971
Citation profile
35 state decisions
How this case has been cited
Cited by 35 later decisions — most recently January 2022 · most notably 93 Md. App. 422 - Lamb v. State (1992), Dishman v. State (1998)
35 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 Commonwealth v. Welansky · Neusbaum v. State · 4 Md. App. 236 - State v. Gibson · Palmer v. State · Craig 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]here a charge of involuntary manslaughter is predicated on negligently doing some act lawful in itself, the negligence necessary to support a conviction must be gross or criminal, viz., such as manifests a wanton or reckless disregard of human life.”
5 later decisions quote this exact passage · from the majority“an unintentional killing done without malice, (1) by doing some unlawful act endangering life but which does not amount to a felony, or (2) in negligently doing some act lawful in itself, or (3) by the negligent omission to perform a legal duty.”
2 later decisions quote this exact passage · from the majoritye.g. State v. Thomas · State v. Pagotto“It has long been stated that where the charge of involuntary manslaughter is predicated upon the allegation that the defendant committed a lawful act in a negligent manner, a conviction of manslaughter will not lie on a showing of simple negligence or misadventure or carelessness but must rather be predicated upon that degree of aggravated negligence which is termed “gross” negligence. In determining whether a defendant’s actions constituted gross negligence, we must ask whether the accused’s conduct, “under the circumstances, amounted to a disregard of the consequences which might ensue and indifference to the rights of others, and so was a wanton and reckless disregard for human life.” Stated otherwise, the accused must have committed “acts so heedless and incautious as necessarily to be deemed unlawful and wanton,” manifesting such a gross departure from what would be the conduct of an ordinarily careful and prudent person under the same circumstances so as to furnish evidence of an indifference to consequences. It is only conduct which rises to this degree of gross negligence upon which a conviction of involuntary manslaughter can be predicated.”
1 later decision quote this exact passage · from the majority
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.