175 Md. App. 588 - Coates v. State’s Empirical Analysis
2007
Citation profile
13 state decisions
How this case has been cited
Cited by 13 later decisions — most recently February 2023
13 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 Crawford v. Washington · Kliewer v. New Jersey · United States v. Eichman · Vasquez v. Harris · Beahm v. Shortall
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Simply put, we cannot glean from this record the basis on which Jazmyne would have understood that she was being seen for medical treatment or diagnosis, some fourteen months after the last sexual abuse incident, and three weeks after her disclosure to her mother of what had occurred. For example, there is no indication that Jazmyne had any understanding, at her age, that she was at continued risk of developing a latent, sexually transmitted disease or HIV. Moreover, most eight-year-olds would not discern emergent circumstances or medical necessity in the absence of any medical complaints or symptoms. And Jazmyne’s inquiry as to whether Bresee would find Coates suggest that Jazmyne did not perceive that there was a medical purpose-—or even a dual purpose—for the examination.””
1 later decision quote this exact passagee.g. State v. Coates“[Gjiven the long delay between the last incident of abuse and the examination, coupled with the fact that [the child] was not exhibiting any symptoms of illness, there is no indication that she understood that there was a medical purpose for the examination. The significant lapse of time between the alleged abuse and [the child’s] statements to the [SAFE nurse] raises concerns as to the circumstantial guarantee of reliability that undergirds the [hearsay] exception. Because we cannot say that [the child] comprehended that there was a medical purpose for [the SAFE nurse’s] examination, the statements were not admissible under Rule 5-803(b)(4).”
1 later decision quote this exact passage
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.