Wiggins v. State’s Empirical Analysis

Citation profile

4 federal appellate · 4 district · 106 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 121 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““[T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” (emphasis in original).”

   4 later decisions quote this exact passage
   e.g. Oken v. State · Metheny v. State

2. “[p]rior to sentencing, the State moved in limine to exclude evidence of its offer of a life sentence in exchange for a guilty plea. Wiggins had indicated an intention to introduce evidence of this offer during the sentencing hearing. The court ruled that while the offer, if admitted in evidence, would “mitigate [] in favor of the defendant,” it was not admissible before the sentencing authority as it would seriously cripple the plea negotiation process in capital sentencing prosecutions. Wiggins argues that the State’s plea offer was properly admissible as mitigating evidence because, under Lockett v. Ohio, 438 U.S. 586 , 98 S.Ct. 2954 , 57 L.Ed.2d 973 (1978), the sentencing authority in capital cases must be permitted to consider any relevant mitigating factor, i.e., anything that might serve as a basis for a sentence less than death. Specifically, Wiggins says that the State’s offer, for whatever reason it was made, demonstrated its belief that a life sentence was appropriate in the case and had this been known to the sentencing jury it would not have imposed the death sentence. In Lockett, 438 U.S. at 605 , 98 S.Ct. 2954 .. .the Supreme Court held that “The Eighth and Fourteenth Amendments require that the sentencer, in all but the rarest kind of capital case, not be precluded from considering, as a mitigating factor, any aspect of a defendant’s character or record and any of the circumstances of the offense that the defendant proffers as a basis for a sentence less than d”

   1 later decision quote this exact passage
   e.g. 164 F. Supp. 2d 538 - Wiggins v. Corcoran

3. “Wiggins next contends that the trial court erred in excluding from the consideration of the sentencing jury, as relevant mitigating evidence, a three-volume collection of documents detailing potentially capital cases where a sentence less than death was imposed. He draws attention to Art. 27, § 414(e)(4), which requires this Court in every case where the death sentence has been imposed to compare it to those imposed “in similar cases”'to ensure that it is not excessive or disproportionate, “considering both the crime and the defendant.” Wiggins claims that sentence proportionality is an appropriate consideration for the sentencing authority as well, and that the proffered evidence should have been admitted for its consideration. He claims that, lacking this information, the sentencing jury did not have relevant information to make its sentencing decision' — information which, he says, is traditionally relevant in determining the appropriate sentence and which would have assisted a jury in determining the weight to be given to aggravating factors in weighing them against mitigating circumstances. In this regard, Wiggins says that had the jury known of the frequency with which life imprisonment is imposed in murder cases of a more extreme nature than his own, it might well have determined to return a sentence less than death. In White v. State, 322 Md. 738 , 589 A.2d 969 (1991), we noted that proportionality review in capital sentencing cases under Art. 27, § 414(e)(4) requires”

   1 later decision quote this exact passage
   e.g. 164 F. Supp. 2d 538 - Wiggins v. Corcoran