State v. Stanga’s Empirical Analysis

Citation profile

44 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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[Detective] Lubbers said numerous times that he was there to listen, making comments such as “it’s between you and me,” “I’m here to listen to your side,” and “you need to get this off your chest,” all as part of his interrogation technique. Stanga said repeatedly that he went to the house to “talk” to Judy, but he also admitted hitting her, and then divulged having in mind a plan to kill her. Throughout the interview, he sought assurances on whether he could trust the detective-whether he could speak “straight up.” When Stanga seemed to forget who he was talking to, Lubbers reminded him, “Well, T am the cop.” At one point, Stanga told the detective, “I know you’re here to get something against me.” But Lubbers responded, “No, I’m here for you and I to talk.” After hearing this, Stanga said, “Okay. I’m going to tell you straight up, and if it goes any further than me and you, then I won’t tell. I don’t know.” Lubbers responded, “You can trust me straight up. Go ahead.” Still needing more assurance, Stanga asked, “What I say to you, suppose it goes to everybody?” As the videotape ran and as other officers watched unseen, Lubbers replied, “Between you and me. There’s nobody else in the room here. It’s between you and me.” Stanga confided again that he was thinking about killing Judy when he broke into her home. Later, seeming to understand that his statement could be used against him, Stanga said, “I’ll tell you the truth and you tell the judge.” Yet at the end of the interview”

   1 later decision quote this exact passage
   e.g. 186 Md. App. 631 - Lee v. State

2. “After giving the Miranda warning to Stanga, [Detective] Lubbers repeatedly contradicted the admonition that anything Stanga said could be used against him. Lubbers told Stanga twelve times that what was said during the interrogation was between the two of them. . In the suppression hearing and in the trial, Lubbers admitted that he lied to Stanga when he told him that what he said would not go any further than the interview room. Some of the detective’s comments were equivocal and, might fairly be characterized as sympathetic colloquialisms ..., but several of the assurances clearly crossed the line. When Stanga said that he knew that Lubbers was there to get something against him and Lubbers responded “No, I’m here for you and I to talk,” that and comments like it nullified the Miranda warnings. Although trickery is sometimes a legitimate interrogation technique, Miranda warnings are a “concrete” prerequisite to custodial interrogation and may not be manipulated through deception.”

   1 later decision quote this exact passage
   e.g. 164 Md. App. 1 - Logan v. State

3. “The harmless error doctrine preserves the essential purpose of criminal trials: to decide a defendant’s guilt or innocence. The rule promotes public respect for the criminal process by focusing on the underlying fairness of the trial rather than on the virtually inevitable pres- enee of immaterial error. The harmless error rule governs ... provided the court is able to declare a belief beyond a reasonable doubt that the error was harmless and did not contribute to the verdict obtained. [Hjarmlessness must ... be determined on the basis of the remaining evidence. ■”

   1 later decision quote this exact passage
   e.g. State v. Bowker