Brooks v. State’s Empirical Analysis
1979
Citation profile
104 state decisions
How this case has been cited
Cited by 104 later decisions — most recently April 2020 · most notably Lewis v. State (1979), State v. Hawkins (1992)
104 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 Blockburger v. United States · Brown v. Ohio · Iannelli v. United States · Bell v. United States · Prince v. United States
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 104 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“even though offenses may be separate and distinct under the required evidence test, courts occasionally find as a matter of statutory interpretation that the Legislature did not intend, under the circumstances involved, that a person could be convicted of two particular offenses growing out of the same act or transaction.”
11 later decisions quote this exact passage · from the majoritye.g. Pair v. State · Dillsworth v. State““focuses upon the elements of the two crimes rather than upon the actual evidence adduced at trial. The ‘required evidence’ refers to that evidence needed, as a matter of law, to prove the crimes. This was explained in Thomas v. State, 277 Md. 257, 267 , 353 A.2d 240 (1976): ‘The required evidence is that which is minimally necessary to secure a conviction for each statutory offense. If each offense requires proof of a fact which the other does not, or in other words, if each offense contains an element which the other does not, the offenses are not the same for double jeopardy purposes even though arising from the same conduct or episode.’ ” 284 Md. at 420 , 397 A.2d at 598 (emphasis in original; citations omitted).”
8 later decisions quote this exact passage · from the majoritye.g. Pair v. State · Dillsworth v. State“[A]lthough the required evidence test is the normal standard for deciding the allowability of separate sentences, the Legislature may not in certain circumstances intend that separate sentences be imposed for two offenses growing out of the same transaction, even though the two offenses are clearly distinct under the required evidence test. On the other hand . . . even though two offenses may be deemed the same under the required evidence test, separate sentences may be permissible, at least where one offense involves a particularly aggravating factor, if the Legislature expresses such an intent.”
2 later decisions 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.