Hebron v. State’s Empirical Analysis

Citation profile

1 district · 96 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 97 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Circumstantial evidence is not like a chain which falls when its weakest link is broken, but is like a cable. The strength of the cable ... does not depend upon one strand, but is made up of a union and combination of the strength of all its strands. No one wire in the cable that supports the suspension bridge across Niagara Falls could stand much weight, but when these different strands are all combined together, they support a structure which is capable of sustaining the weight of the heaviest engines and trains. We therefore think it is erroneous to speak of circumstantial evidence as depending on links, for the truth is that in cases of circumstantial evidence each fact relied upon is simply considered as one of the strands and all of the facts relied upon should be treated as a cable.”

   3 later decisions quote this exact passage
   e.g. 134 Md. App. 113 - Morgan v. State · 188 Md. App. 110 - Clark v. State

2. “The cases referring to circumstantial evidence not excluding every reasonable hypothesis of a defendant’s innocence are cases in which there is circumstantial evidence of the defendant’s guilt and other evidence, either circumstantial or direct, tending to negate that evidence and no basis upon which a rational finder of fact could return a verdict of guilty without speculating as to which of the two versions is the correct version. A jury faced with that state of evidence could not logically nor lawfully, return a guilty verdict; hence as the Court of Special Appeals pointed out, given that scenario, “there is nothing for the jury to decide and, upon proper motion, the judge is duty-bound as a matter of law, to enter a judgment of acquittal.””

   3 later decisions quote this exact passage
   e.g. 118 Md. App. 590 - Stouffer v. State · 134 Md. App. 113 - Morgan v. State

3. “[C]ircumstantial evidence need not be such that no possible theory other than guilt can stand.... It is not necessary that the circumstantial evidence exclude every possibility of the defendant’s innocence, or produce absolute certainty in the minds of jurors---- While it must afford the basis for an inference of guilt beyond a reasonable doubt, it is not necessary that each circumstance, standing alone, be sufficient to establish guilt, but the circumstances are to be considered collectively.”

   3 later decisions quote this exact passage
   e.g. Denson v. State · 189 Md. App. 230 - Harris v. State