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← 286 Md. 444 - Countess v. State

Countess v. State’s Empirical Analysis

1979

Citation profile

107
cited by 107 later decisions
4
states following
April 2021
most recently cited

105 state decisions

How this case has been cited

Cited by 107 later decisions — most recently April 2021 · most notably State v. Bell (1998), Goins v. State (1982)

105 state decisions

750197919801990200020102020decided

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 Johnson v. Zerbst · Fay v. Noia · Duncan v. State of Louisiana · Curtis v. State · Berry v. Scott

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

  1. “What the Rule contemplates is that the defendant have a basic understanding of the nature of a jury trial. We think that this understanding is generally satisfied when the defendant entitled to a jury trial knows that he has the right to be tried by a jury of 12 persons or by the court without a jury; that whether trial is by a jury or by the court, his guilt must be found to be beyond a reasonable doubt; that in a jury trial all 12 jurors must agree that he is so guilty but in a court trial the judge may so find.”
    10 later decisions quote this exact passage · from the majority
  2. “If the defendant elects to be tried by the court, the trial of the case on its merits before the court may not proceed until the court determines, after inquiry of the defendant on the record, that the defendant has made his election for a court trial with full knowledge of his right to a jury trial and that he has knowingly and voluntarily waived the right. If the court determines otherwise, it shall give the defendant another election pursuant to this Rule.”
    8 later decisions quote this exact passage · from the majority
  3. “"Although Fairbanks did indicate on the record that he understood what a jury trial was and that he understood he had the absolute right to a jury trial and wished to waive it, the record disclosed nothing further. The record is not sufficient to establish that he was aware that `before a finding of guilty in a jury trial all 12 jurors must find that [he was] guilty beyond a reasonable doubt,' but that in a court trial he could be convicted by the judge alone so finding. Thus, there was not a showing on the record that Fairbanks had the `full knowledge of his right to a jury trial' contemplated by § d. " (Emphasis added.)”
    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.