23 Md. App. 457 - Irvin v. State’s Empirical Analysis
1974
Citation profile
42 state decisions
How this case has been cited
Cited by 42 later decisions — most recently September 2012 · most notably State v. Pagano (1996), Irvin v. State (1975)
42 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 Dutton v. Evans · Krulewitch v. United States · Time, Inc. v. Bon Air Hotel, Inc. · Haines v. Kerner · 3 Md. App. 11 - Boone 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.
“The second prerequisite that must be met in order to utilize the coconspirators hearsay exception is that the act or declaration must have been made during the “pendency” of the conspiracy. By “pendency” we mean the duration of the unlawful agreement, but that does not mean that the conspiracy continues ad infinitum. The duration of a conspiracy is restricted to the accomplishment of its “main aim”. Krulewitch v. United States, 336 U.S. 440 , 69 S.Ct. 716 , 93 L.Ed. 790 (1949).”
1 later decision quote this exact passage · from the majority“[T]he State must also demonstrate that the declaration or act of the coconspirator was made or done in furtherance of the conspiracy and during its pendency. We observe that the “furtherance” requirement is interpreted broadly. Levie, Hearsay and Conspiracy 52 Mich.L.Rev. 1159, 1168 (1954) puts it this way: “If some connection is established between the declaration and the conspiracy then the declaration is taken as in furtherance of the conspiracy.””
1 later decision quote this exact passage · from the majority“In Maryland the State may either appeal the dismissal of an indictment or seek a new indictment or both so long as the State’s action is not deemed to be oppressive and thus a possible violation of due process of law. In sum, the State must act in good faith.”
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.