235 Md. App. 392 - State v. Armstead’s Empirical Analysis

Citation profile

3 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[w]hen a trial court injects erroneously a CSI effect [message], in order for a court to find harmless error, the court must be satisfied beyond a reasonable doubt that the abuse of discretion was harmless. Hall , 437 Md. at 540 , 87 A.3d at 1291 ; [ State v. ] Stringfellow , 425 Md. [461,] 474, 42 A.3d [27,] 35 [ (2012) ]. We must, "upon an independent review of the record, ' "be satisfied that there is no reasonable possibility' " that the assumed error caused impermissibly the guilty verdict." Stringfellow , 425 Md. at 474 , 42 A.3d at 35 (citing Lee v. State , 405 Md. 148 , 163, 950 A.2d 125 , 134 (2008) (quoting Dorsey v. State , 276 Md. 638 , 659, 350 A.2d 665 , 678 (1976) ) ). The record must demonstrate that the reference to a lack of scientific evidence was not material to the contested issue . Compare Hall , 437 Md. at 540 , 87 A.3d at 1291 (in an armed carjacking case, the Court held a CSI effect jury instruction regarding the lack of scientific evidence, i.e., a photograph of the defendant controlling the victim's car, was not material or necessary to "shed any light" on how the defendant gained control of the victim's car), and Evans , 174 Md. App. at 570, 922 [A.2d] at 632-33 (the lack of scientific evidence was not critically important to the case; the State could prove guilt beyond a reasonable doubt with an eyewitness's testimony and identification by two detectives involved directly in the transaction), with Atkins , 421 Md. at 50 , 26 A.3d at 988 (the missi”

   1 later decision quote this exact passage · from the majority
   e.g. 236 Md. App. 397 - Taylor v. State

2. “[n]either the trial court nor the parties' counsels repeated the anti-CSI effect message (as such) during the trial. [The trial court administered curative instructions to the jury as well as reiterated] the State's burden of proof later in its [ ] instructions [to the jury]. These instructions ... assisted in dislodging any residual bits of potential prejudice concerning the weight of presented (or unpresented) evidence and reminded the jury of the State's fixed burden of proof .... * * * Armstead was arrested in Georgia (where he had been living under the alias 'James L. Jefferson' for the two weeks after the police discovered Paige's body). It was unlikely at that point in time that DNA evidence of Paige would be located on Armstead's person. [An eyewitness] saw Armstead [and other unidentified suspects] ... [ and Armstead made a voluntary and inculpatory statement during an interrogation to a police detective] ....”

   1 later decision quote this exact passage · from the majority
   e.g. 236 Md. App. 397 - Taylor v. State

3. “[t]he current state of scholarly research regarding the so-called "CSI effect" in litigation contexts remains inconclusive regarding the effect's authenticity. Robinson , 436 Md. at 79-81 [578-80], 84 A.3d at 578-80 [79-81], explicated that "in the last two years since [the Court of Appeals] issued Stabb , legal and empirical proof of the existence of a "CSI effect is still wanting." (elaborating further on the current state of CSI effect scholarly research); see Stabb , 423 Md. at 467 -71 , 31 A.3d at 930-32 (the Court discusses, at length, the " 'CSI Effect' Redux"); Atkins , 421 Md. at 457 -62 , 26 A.3d at 993-96 (Harrell, J., concurring) (engaging in a thorough analysis of the CSI Effect scholarly research legal landscape); Charles & Drake , 414 Md. at 731-33, 997 A.2d at 157-59 (analyzing the scholarly basis regarding the impact that viewing forensic crime dramas has upon juror behavior).”

   1 later decision quote this exact passage · from the majority
   e.g. 236 Md. App. 397 - Taylor v. State