20 Md. App. 577 - Smith v. State’s Empirical Analysis
1974
Citation profile
22 state decisions
How this case has been cited
Cited by 22 later decisions — most recently October 2014
22 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 Jackson v. Denno · Sims v. State of Georgia · 9 Md. App. 15 - Metz v. State · 12 Md. App. 684 - Walker v. State · State v. Hutchinson
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In a prosecution for arson as in other criminal cases, the State must prove the corpus delicti, viz., burning with a criminal design. Not only must the fact of the fire be shown; it must also be established that it was willfully and maliciously set. The State must prove a criminal design beyond a reasonable doubt. Proof of the defendant’s criminal agency, although essential for conviction, is not part of the corpus delicti. Davis v. State, 202 Md. 463 , 97 A. 2d 303 (1953); Bollinger v. State, 208 Md. 298 , 117 A. 2d 913 (1955); McDowell v. State, 231 Md. 205 , 189 A. 2d 611 (1963); Hughes v. State, 6 Md. App. 389 , 251 A. 2d 373 (1969). Other relevant rules of law in arson cases that may be encapsulated from the cases cited and their underlying authorities are these: 1. The character of the evidence to prove the corpus delicti, and its sufficiency for that purpose, depend largely upon the circumstances of each particular case; and the law recognizes that since a burning is almost invariably clandestine, the prosecution must usually depend upon circumstantial evidence. 2. An extrajudicial confession of guilt of arson uncorroborated by other evidence of the corpus delicti is not sufficient to warrant a conviction. 3. With respect to the nature and quantum of the evidence needed to corroborate the extrajudicial confession: (a) Such evidence need not be full and positive, and may be circumstantial in nature when direct evidence is not available. (b) It need not establish by its”
1 later decision quote this exact passage · from the majority“' “To be sufficient in law to justify a conviction, the admissible evidence adduced must show directly, or circumstantially, or support a rational inference of, the facts to be proved from which the trier of fact could fairly be convinced, beyond a reasonable doubt, of the defendant’s guilt of the offense charged.””
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.