Ballard v. State’s Empirical Analysis

Citation profile

22 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[t]he Maryland corroboration requirement, operating in homicide cases as above described, does not require that every element of the consummated crime be independently established. Accordingly, the Court of Special Appeals in Ball v. State, 57 Md.App. 338 , 470 A.2d 361 (1984), modified on other grounds sub nom. Wright v. State, 307 Md. 552 , 515 A.2d 1157 (1986), correctly rejected an argument in a felony murder case that there was insufficient corroboration because the only evidence of an attempted robbery was the statement of the appellant. “The requirement that there be some corroborating evidence tending to establish the corpus delicti generally, does not establish an independent corroboration requirement as to each component element of the corpus delicti.” 57 Md.App. at 351 , 470 A.2d at 368 ....”

   2 later decisions quote this exact passage · from the dissent
   e.g. Miller v. State · 155 Md. App. 181 - Riggins v. State

2. “In his confession Woods admitted that he shot Michael Boyd “three or four times” at point blank range in consummation of a plan to kill Boyd. This admission was corroborated as required with respect to the corpus delicti of murder in the first degree. Evidence apart from the confession established that Michael Boyd was indeed dead. His body was found. A doctor in the Department of Post Mortem Examiners testified that the cause of death was “the gunshot wounds.” [ ] The gunshot wounds were enough to show that the manner of death was homicide — that Boyd’s death was not by accident or suicide but was caused criminally by someone. With this corroboration the confession was enough to meet the test for the sufficiency of evidence to sustain the conviction of murder in the first degree.”

   2 later decisions quote this exact passage
   e.g. 194 Md. App. 629 - Cox v. State · Cox v. State

3. ““The traditional formulation of the requirement, still applied by most jurisdictions, demands that there be some evidence other than the confession that tends to establish the corpus delicti.... There is some dispute regarding the definition of corpus delicti, which literally means the ‘body of the crime.’ To establish guilt in a criminal case, the prosecution must ordinarily show that (a) the injury or harm constituting the crime occurred; (b) this injury or harm was done in a criminal manner; and (c) the defendant was the person who inflicted the injury or harm. Wigmore maintains that corpus delicti means only the first of these, that is, “the fact of the specific loss or injury sustained,” and does not require proof that this was occasioned by anyone’s criminal agency. ...” Most courts, however, define corpus delicti as involving both (a) and (b). This means that the corroborating evidence must tend to show the harm or injury and that it was occasioned by criminal activity. It need not, however, in any manner tend to show that the defendant was the guilty party. Thus in a homicide case, the corpus delicti consists of proof that the victim died and that the death was caused by a criminal act, but it need not tend to connect the defendant on trial with that act. The traditional approach has been to require that the elements of the offense be carefully distinguished and that the corroborating evidence tend to show each of those elements. A growing number of courts, however, a”

   1 later decision quote this exact passage · from the dissent
   e.g. 155 Md. App. 181 - Riggins v. State