205 Md. App. 607 - Kamara v. State’s Empirical Analysis

Citation profile

12 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The independent source doctrine ... applies when the evidence actually has been discovered by lawful means. Its focus is on what actually happened—was the discovery tainted by the illegal search? ... [UJnder the independent source doctrine, evidence that was in fact discovered lawfully, and not as a direct or indirect result of illegal activity, is admissible.”

   1 later decision quote this exact passage
   e.g. 216 Md. App. 235 - Williams v. State

2. “"[1] the defendant's proximity to the drugs, [2] whether the drugs were in plain view of and/or accessible to the defendant, [3] whether there was indicia of mutual use and enjoyment of the drugs, and [4] whether the defendant has an ownership or possessory interest in the location where the police discovered the drugs."”

   1 later decision quote this exact passage
   e.g. 239 Md. App. 495 - Spell v. State

3. “There are three circumstances, however, in which evidence obtained after initial unlawful conduct can be purged of taint: “... Second, the taint will be purged upon a showing that the evidence was derived from an independent source....””

   1 later decision quote this exact passage
   e.g. 216 Md. App. 235 - Williams v. State