18 Md. App. 150 - Carter v. State’s Empirical Analysis
1973
Citation profile
3 federal appellate · 32 state decisions
How this case has been cited
Cited by 35 later decisions — most recently January 2010 · most notably 24 Md. App. 128 - Andresen v. State (1975), 34 Cal. 3d 541 - People v. Ramirez (1983)
3 federal appellate · 32 state decisions — followed in 10 states
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 Whiteley v. Warden, Wyoming State Penitentiary · JOHNSON, ETC. v. State · 8 Md. App. 204 - Cleveland v. State · 17 Md. App. 376 - Collins v. State · 4 Md. App. 222 - Gibson 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.
“Probable cause existing at the time of an arrest is the measure of the legality of the arrest. Evans v. State, 11 Md.App. 451 , 274 A.2d 653 (1971). It is settled that probable cause may be based on information within the collective knowledge of the police. Collins v. State, 17 Md.App. 376 , 302 A.2d 693 (1973); Hebron v. State, 13 Md.App. 134 , 281 A.2d 547 (1971). Thus, even though an arresting officer personally may lack probable cause to justify an arrest, the State can show that the police team, collectively possessed knowledge sufficient to establish probable cause. Thompson v. State, 15 Md.App. 335, 343 , 290 A.2d 565 (1972); Collins v. State, supra.”
2 later decisions quote this exact passage · from the majority“Probable cause existing at the time of an arrest is the measure of the legality of the arrest.... It is settled that probable cause may be based on information within the collective knowledge of the police.... [¶] The problem in this case, however, is that the information contained within the collective knowledge of the Baltimore Police Department which was communicated to the arresting officer in the field was completely erroneous, i.e., neither the tags nor the vehicle that he had stopped were stolen property at the time of the arrest.... It is one thing to permit an arrest to be made on information residing in the police files; it is another to sanction an arrest the probable cause for which is based on police information which is not true.”
1 later decision quote this exact passage · from the majority“must be charged with the knowledge that the report was, in effect, rescinded when members of the Baltimore City Police Department recovered the car shortly after it was stolen. Accordingly, the erroneous information transmitted [to the arresting officer] and on the basis of which he arrested the appellant was clearly insufficient to show probable cause.”
1 later decision quote this exact passage · from the majoritye.g. Ott 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.