Bartram v. State’s Empirical Analysis

Citation profile

60 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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[t]he grand jury’s sources of information are widely drawn, and the validity of an indictment is not affected by the character of the evidence considered. Thus, an indictment valid on its face is not subject to challenge on the ground that the grand jury acted on the basis of inadequate or incompetent evidence. ... Everhart v. State, 274 Md. 459, 487 [ 337 A.2d 100 ] (1975).”

   2 later decisions quote this exact passage · from the majority
   e.g. 143 Md. App. 645 - State v. Deleon · 140 Md. App. 540 - Clark v. State

2. “The authorities cited by defendants, in which indictments were quashed because the accused was called before the grand jury and examined, or because private counsel was permitted to appear and address the grand jury, are not in point. In those cases the indictments were quashed, not because incompetent evidence was received, but because the proceedings of the grand jury were unconstitutional and unlawful. Clearly, if the grand jury were improperly impaneled, or if certain classes of persons unlawfully were excluded from serving thereon, the matter could be brought to the attention of the court, and disposed of, by a motion to quash the indictment. The two propositions are radically different. It is one thing to quash an indictment because the accused, in violation of his constitutional right, is brought before the grand jury and browbeaten or maltreated, or because private counsel is permitted to harangue the jurors, or because other like fundamental wrongs are permitted, and quite another thing to quash an indictment because a witness is asked concerning facts which mayhap do not tend to prove the charge which the grand jury is to inquire into. The one reaches to the organizational or fundamental power of the grand jury to act; the other, granting that the grand jury was properly impaneled and had the power to proceed, involves the proposition that it acted upon incompetent evidence, and therefore reached an irrational conclusion.”

   1 later decision quote this exact passage · from the majority
   e.g. 140 Md. App. 540 - Clark v. State

3. “The grand jury may compel the production of evidence or the testimony of witnesses as it considers appropriate .... "It is a grand inquest, a body with powers of investigation and inquisition, the scope of whose inquiries is not to be limited narrowly by . . . forecasts of the probable result of the investigation, or by doubts whether any particular individual will be found properly subject to an accusation of crime.” Blair v. United States, 250 U.S. 273, 282 [ , 39 S. Ct. 468, 471 , 63 L. Ed. 979, 983 ] (1919). [United States v. Calandra, 414 U.S. 338, 343 , 94 S. Ct. 613, 617 , 38 L. Ed. 2d 561, 568-69 (1974).]”

   1 later decision quote this exact passage · from the majority
   e.g. In Re Special Investigation No. 185