Veney v. State’s Empirical Analysis
1962
Citation profile
66 state decisions
How this case has been cited
Cited by 66 later decisions — most recently February 2001 · most notably Newton v. State (1977), State v. Lancaster (1993)
66 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 Gavieres v. United States · Adams v. State of Maryland · Commonwealth Ex Rel. Moszczynski v. Ashe · Williams v. State · Gilpin 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 66 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““But this does not mean that the later and more modern concept of merger of offenses, whether it be considered under such terms as 'double jeopardy,’ ‘merger/ or ‘divisibility of offenses’ fails to play an important role in criminal prosecutions today. For, as this Court pointed out when it quoted R.C.L. in Gilpin, supra (142 Md. p. 469) to the effect: “Tt [common law merger] has no application where both crimes are misdemeanors or both are felonies, though one may be of a much graver character than the other and punishable with much greater severity; but in such a case another principle applies, that is if the lesser felony [or offense] is a necessary ingredient of the other, a conviction of one will bar a prosecution for the other by virtue of the twice in jeopardy rule. * * *” ’ See also Williams v. State, supra [ 205 Md. 470 , 109 A. 2d 89 .] “* * C.J.S., Criminal Law, § 10, states the true test of whether one criminal offense has merged into another is held to be not whether the two criminal acts are successive steps of the same transaction, but whether one crime necessarily involves the other.””
2 later decisions quote this exact passage · from the majoritye.g. Bennett v. State · Brooks v. State““The required evidence is that which is minimally necessary to secure a conviction for each ... offense. If each offense requires proof of a fact which the other does not, or in other words, if each offense contains an element which the other does not, the offenses are not the same for double jeopardy [and merger] purposes, even though arising from the same conduct or episode. But, where only one offense requires proof of an additional fact, so that all elements of one offense are present in the other, the offenses are deemed to be the same for double jeopardy [and merger] purposes.””
1 later decision quote this exact passage · from the majoritye.g. Williams 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.