21 Md. App. 61 - Ayre v. State’s Empirical Analysis
1974
Citation profile
2 district · 40 state decisions
How this case has been cited
Cited by 42 later decisions — most recently September 2016 · most notably Ford v. State (1993), Robinson v. State (1999)
2 district · 40 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 Coffin v. United States · Bryant v. State · Seidman v. State · State v. Lassotovitch · Leon 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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““When a statute creates an offense and specifies several different acts, transactions, or means by which it may be committed, an indictment for violation thereof may properly allege the offense in one count by charging the accused in conjunctive terms with doing any or all of the acts, transactions, or means specified in the statute.””
5 later decisions quote this exact passage · from the majoritye.g. Guy v. State · Albrecht v. State““While the rule is that an indictment or information should not charge the commission of two or more substantive offenses in the same count, it is not objectionable to charge in one count several related acts which enter into and constitute one offense, although when separately considered they may be distinct offenses.””
2 later decisions quote this exact passage · from the majority““When a statute creates an offense and specifies several different acts, transactions, or means by which it may be committed, an indictment for violation thereof may properly allege the offense in one count by charging the accused in conjunctive terms with doing any or all of the acts, transactions, or means specified in the statute. This is the rule of Leon v. State, 180 Md. 279, 286 [, 23 A.2d 706, 710 (1942)] as construed in Morrissey v. State, 9 Md. App. 470, 475-476 [, 265 A.2d 585, 587-88 (1970)]. See Bonneville v. State, 206 Md. 302 [, 111 A.2d 669 (1955)]; Sturgill v. State, 191 Md. 75 [, 59 A.2d 763 (1948)]; Thomas v. State, 173 Md. 676 [, 197 A. 296 (1938)]; Reynolds v. State, 141 Md. 637 [, 119 A. 457 (1922)]; Pritchett v. State, 140 Md. 310 [, 117 A. 763 (1922)]; Stearns v. State, 81 Md. 341 [, 32 A. 282 (1895)]. See also 41 Am. Jur. 2d, Indictments and Informations, § 218. We said in Morrissey , at 476 [, 265 A.2d at 588 ]: While the rule is that an indictment or information should not charge the commission of two or more substantive offenses in the same count, it is not objectionable to charge in one count [in conjunctive terms] several related acts which enter into and constitute one offense, although when separately considered they may be distinct offenses. *** Thus, if the acts alleged are of the same nature and so connected that they can be construed as stages in one criminal transaction, they may be joined in one count, although separately considered they a”
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.