Spratt v. State’s Empirical Analysis

1989

Citation profile

cited by 71 later decisions

states following

July 2015

most recently cited

1 federal appellate · 2 district · 66 state decisions

How this case has been cited

Cited by 71 later decisions — most recently July 2015 · most notably Morris v. Prince George's County (1990), Ford v. State (1993)

1 federal appellate · 2 district · 66 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 Kaczorowski v. Mayor of Baltimore · Stanley v. State · Felkner v. State · Washington National Arena Ltd. Partnership v. Comptroller of Treasury · Guardian Life Insurance Co. of America v. Insurance Commissioner

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

“[W]e hold that it is necessary for the trier of fact to make a finding as to value when the State is seeking a conviction under Art. 27, § 111(c). It was essential for the jury to be instructed as to value in the present case. Prior to the enactment of the 1985 amendments, neither § 111 nor any of its statutory predecessors referred to the amount of the value of the property destroyed. The present statutory scheme permits the State to proceed under the lesser offense, subsection (b), and avoid the possibility of a misdemeanor jury trial on the merits. However, if the State wishes to pursue the more serious offense under subsection (c), it must specifically charge and prove the value of the destroyed property, greater than $300.”
3 later decisions quote this exact passage
e.g. Hagans v. State · Wadlow v. State
““Maryland case law generally supports the notion that where a criminal statute separates the offense by a value determination, it is necessary for the State to prove value in terms of the sufficiency of the evidence.””
2 later decisions quote this exact passage
e.g. Graham v. State · Hagans v. State
“(A) Any person who shall wilfully and maliciously destroy, injure, deface or molest any real or personal property of another shall be deemed guilty of a misdemeanor [and, upon conviction thereof, shall be subject to imprisonment for a period of not more than three years or to a fine not more than $2,500, or to both imprisonment and fine]. (B) IF THE PROPERTY DEFACED, DESTROYED, INJURED, OR MOLESTED HAS A VALUE OF LESS THAN $300, THE PERSON WHO VIOLATES THIS SECTION, ON CONVICTION, IS SUBJECT TO A FINE NOT EXCEEDING $500 OR IMPRISONMENT NOT EXCEEDING 60 DAYS OR BOTH. (C) IF THE PROPERTY DEFACED, DESTROYED, INJURED, OR MOLESTED HAS A VALUE OF $300 OR MORE, THE PERSON WHO VIOLATES THIS SEC TION, ON CONVICTION, IS SUBJECT TO A FINE NOT EXCEEDING $2,500 OR IMPRISONMENT NOT EXCEEDING 3 YEARS OR BOTH.”
1 later decision quote this exact passage
e.g. Wadlow v. State

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.