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← 232 Md. App. 382 - Grimm v. State

232 Md. App. 382 - Grimm v. State’s Empirical Analysis

2017

Citation profile

5
cited by 5 later decisions
1
states following
February 2021
most recently cited

5 state decisions

Relationships

Relies on Illinois v. Gates · Carroll v. United States · Ornelas v. United States · Whren v. United States · Texas v. Brown

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

  1. “Whether Ace was-at the time of the [dog] scan of Grimm's vehicle-a well-trained or reliable [drug detection] dog, whose alerts could be relied upon by Officer Keightley as indicating that there was a fair probability that [Grimm's] vehicle contained one of illegal drugs [that] Ace had been trained to detect, was a question of fact [that was] properly committed to the adjudicatory skill of the [trial court that] heard the evidence [that was] presented at the hearing on the motion to suppress. An appellate court is ill-equipped to determine the proper amount of weight to be given to various pages of the extensive documentation in evidence regarding a [drug detection] dog's performance during training exercises, or to evaluate the credibility of witnesses, or weigh the conflicting testimony of experts. Such factual determinations are best left to the [trial court that] hears the evidence, and are best reviewed under a "clearly erroneous" standard that gives deference to [the trial court]'s superior opportunity to evaluate credibility and weigh the evidence.”
    1 later decision quote this exact passage · from the majority
  2. “In evaluating whether the State has met th[e] practical and common[sense] standard[ of probable cause], we have consistently looked to the totality of the circumstances.... [T]he court should then evaluate the proffered evidence to decide what all the circumstances demonstrate.”
    1 later decision quote this exact passage
  3. “[i]f a bona fide organization has certified a [drug detection] dog after testing his [or her] reliability in a controlled setting, a court can presume (subject to any conflicting evidence offered) that the [drug detection] dog's alert provides probable cause to search.”
    1 later decision quote this exact passage

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.