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← 339 MD 563 - Goldstein v. State

Goldstein v. State’s Empirical Analysis

1995

Citation profile

43
cited by 43 later decisions
7
states following
June 2021
most recently cited

35 state decisions

How this case has been cited

Cited by 43 later decisions — most recently June 2021 · most notably Armstead v. State (1996), Coleman v. Soccer Ass'n (2013)

35 state decisions

1401995200020102020decided

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 Schneidewind v. ANR Pipeline Co. · Reed v. State · Police Commissioner v. Dowling · Lutz v. State · Rose v. Fox Pool Corp.

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

  1. “"[t]he theory underlying the LTI 20-20 would be familiar to any student of high school physics." * * * [L]aser speed devices operate on the same principle as military radar, which determines distance and changes in distance over time (i.e., speed) by transmitting pulses of microwaves and "measur[ing] the time it takes for a pulse to reach the target and for its echo to return."”
    3 later decisions quote this exact passage
  2. “There are important considerations of judicial economy underlying the practice of limiting Frye-Reed [v. State, 283 Md. 374 , 391 A.2d 364 (1978)], to general processes, rather than brand-name products. If every brand of every instrument were subject to a discrete Frye-Reed evaluation, trial courts would be mired in hearings concerning devices incorporating scientific principles, possibly including calculators and magnifying glasses. See People v. Mendibles, 199 Cal.App.3d 1277 , 245 Cal.Rptr. 553, 563 (1988) (stating that a Frye hearing is not required with respect to a colposcope, which the court characterized as “a weak microscope”). Moreover, the scientific consensus that forms a prerequisite for the admission of evidence would ordinarily be elusive, because, while scientists may be familiar with the general principles underlying a particular device, they may have no occasion to use the device itself. In the instant ease, for example, the LTI 20-20 has little use other than for law enforcement purposes. Consequently, neither of the experts who testified at trial actually used the device in his work.... We believe that the ordinary truth-seeking methods of the adversarial process will suffice to expose design flaws in the devices used to gather evidence, without requiring the courts to place a “Frye-Reed Seal of Approval” on individual brands....”
    1 later decision quote this exact passage
  3. “the mere fact that the General Assembly has declined to adopt a particular proposal does not preclude . . . incorporating the substance of that proposal into the common law or our interpretation of a statute.”
    1 later decision quote this exact passage
    e.g. (1996)

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.