168 Md. App. 22 - Fields v. State’s Empirical Analysis

Citation profile

14 state decisions

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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The State called Detective Canales and questioned him about what he found at the bowling alley when he responded to the call of a shooting and what evidence he collected at the scene. Detective Canales testified that he saw names on the screens at the bowling lanes and wrote all of them down on a piece of paper. The prosecutor argued that the appellant’s nickname, “Sat Dogg,” on the screen at lane 22 was one of several items of evidence at the crime scene that linked the appellant to the scene — including a sweater with his DNA on it, casings from a gun that was under his bed, and a car that looked like his car. The prosecutor did not attempt to use the evidence of the words “Sat Dogg” on the screen at the bowling alley to show that a known declarant believed the appellant was present there, had reason to accurately hold that belief, and therefore was impliedly asserting that factual proposition by entering his nickname on the screen. Unlike the probative value of the medical bill in Berna, dyn, supra, the probative value of the evidence that the appellant’s name was on the television screen did not depend upon the belief of the person who typed the name on the screen, or upon the accuracy of that person’s belief. The prosecutor did not argue that the person who entered the name “Sat Dogg” on the screen only would have done so if he or she believed that the appellant was present in the bowling alley. Indeed, there was no evidence about that person’s belief, because the person”

   1 later decision quote this exact passage
   e.g. 198 Md. App. 1 - Fair v. State

2. “The prosecutor did not attempt to use the evidence of the words “Sat Dogg” on the screen at the bowling alley to show that a known declarant believed [Fields] was present there, had reason to accurately hold that belief, and therefore was impliedly asserting that factual proposition by entering his nickname on the screen. [T]he probative value of the evidence that [Fields’s] name was on the television screen did not depend upon the belief of the person who typed the name on the screen, or upon the accuracy of that person’s belief. The prosecutor did not argue that the person who entered the name “Sat Dogg” on the screen only would have done so if he or she believed that [Fields] was present in the bowling alley. Indeed, there was no evidence about that person’s belief, because the person was not identified. The prosecutor argued only that the crime scene included a bowling lane with the name “Sat Dogg” written above it. [Fields’s] name on the television screen in the bowling alley was not an implied assertion of the factual proposition that [Fields] was present at the bowling alley[.] Because the evidence was not an “assertion,” under Rule 5-801(a), it was not a “statement” under that subsection and hence was not hearsay under Rule 5-801(c). It was admissible non-hearsay evidence. Accordingly, the trial court’s evidentiary ruling was not in error.”

   1 later decision quote this exact passage
   e.g. 196 Md. App. 212 - Carpenter v. State

3. “Immediately before the start of trial, the defense moved in limine to preclude the State from eliciting testimony from Detective Canales that the name “Sat Dogg” appeared on a television screen in the bowling alley or introducing into evidence the detective’s handwritten list showing that the name “Sat Dogg” appeared on the television screen at bowling lane 22. Defense counsel argued that the evidence was hearsay. Specifically, she maintained that the name “Sat Dogg” on the screen was an implied assertion, by an unknown declarant, made out of court, that the appellant was present in the bowling alley that night; and the State was offering the implied assertion in evidence to show its truth. Because the evidence did not fall within any exception to the rule against hearsay, it was inadmissible.”

   1 later decision quote this exact passage
   e.g. 183 Md. App. 122 - Garner v. State