233 Md. App. 265 - Wheeler v. State’s Empirical Analysis

Citation profile

2 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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Given the unique particularities of the packaging of the [suspected heroin]-two orange topped Ziploc baggies and one clear baggie with blue writing on it-which were placed in an intact heat[-]sealed packaging bag, the chance of misidentification was small. Additionally, the [Central Complaint N]umber [that] Detective Bell placed on all the documents was the same [Central Complaint N]umber [that was] placed on the sealed package containing the [suspected heroin]. Also, Detective Bell made only the one drug purchase that day. Moreover, the timing of when Detective Bell returned to the police station, when he began and finished his report, and when the items were retrieved from the laboratory all logically correspond. Thus, the chance that the [suspected heroin that had been] seized by Detective Bell w[as] not the [heroin that had been] analyzed by the chemist is unlikely and remote. Although the gaps in knowledge between when the [suspected heroin was] given to the packaging/submitting agent and when the chemist picked up the [suspected heroin] may have been filled in if the packaging/submitting officer had testified, this did not compel a ruling as a matter of law that the proper chain of custody had not been shown. Rather, it allowed [Wheeler's] counsel to argue in closing that the jury should not credit the drug evidence because of the gap in the chain of custody. Because the evidence presented by the State suggests that it is unlikely that tampering undermined the integrity”

   1 later decision quote this exact passage
   e.g. Wheeler v. State

2. “that the [circuit] court did not abuse its discretion in admitting the drug evidence, for there was sufficient evidence of a reasonable probability to establish that the [heroin that was] analyzed and presented at trial”

   1 later decision quote this exact passage
   e.g. Wheeler v. State

3. “Like other evidentiary rulings, determinations of the adequacy of the chain of custody are left to the sound discretion of the trial court, and we review those rulings for abuse of discretion.”

   1 later decision quote this exact passage
   e.g. Wheeler v. State