Dyson v. State’s Empirical Analysis
1992
Citation profile
31 state decisions
How this case has been cited
Cited by 32 later decisions — most recently August 2021 · most notably Maryland State Police v. Zeigler (1993), Ayers v. State (1994)
31 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 Davis v. Alaska · Needler v. Valley National Bank of Arizona · United States v. Bayer · Mann v. Koob · Continental Airlines, Inc. v. Zimmerman
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Whether good cause is shown; whether the new evidence is significant; whether the jury would be likely to give undue emphasis, prejudicing the party against whom it is offered; whether the evidence is controversial in nature; and, whether the reopening is at the request of the jury or a party.”
4 later decisions quote this exact passage“"We agree that a trial judge must exercise the utmost caution in reopening a case to allow the introduction of additional evidence after the jury has begun deliberating. As the Court of Appeals of New York pointed out, the presentation of evidence must come to an end at some time, and the parties must be forewarned that the desirability of maintaining an orderly trial process militates strongly against receiving evidence at that stage of the trial. A premium must necessarily be placed on preparation and diligence, and evidence which is simply the product of an afterthought, no matter how pertinent it may have been if timely offered, will not, except in the most extraordinary circumstances, be received at this late stage of the proceedings. There is, of course, the very strong probability that evidence offered at this point will be given undue emphasis or prominence by the trier of fact. Moreover, if the evidence is at all disputed or controversial, fair opportunity must be afforded for cross-examination and rebuttal. And it may be difficult, if not impossible, to permit effective argument concerning additional evidence without permitting an entire set of new closing arguments." [11]”
2 later decisions quote this exact passage“Generally, trial judges have broad discretion to reopen a case to receive additional evidence. Hunt v. State, 321 Md. 387, 405-06 , 583 A.2d 218 (1990), cert. denied, ___ U.S. ___, 112 S.Ct. 117 , 116 L.Ed.2d 86 (1991); Guilmore v. State, 263 Md. 268, 290 , 283 A.2d 371 (1971), vacated in part, 408 U.S. 940 , 92 S.Ct. 2876 , 33 L.Ed.2d 763 (1972). We have not heretofore considered, however, the issue presented by this case whether a case may be reopened to permit additional evidence after the jury has begun its deliberations.”
1 later decision quote this exact passage
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.