34 Md. App. 365 - Calhoun v. State’s Empirical Analysis
1977
Citation profile
26 state decisions
How this case has been cited
Cited by 26 later decisions — most recently October 1991 · most notably 89 Md. App. 25 - Allen v. State (1991), 39 Md. App. 44 - Poore v. State (1978)
26 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
Applies 18 U.S.C. § 2510 (Electronic Communications Privacy Act of 1986) · 18 U.S.C. § 2516 (Electronic Communications Privacy Act of 1986) · 18 U.S.C. § 2518 (Electronic Communications Privacy Act of 1986)
Relies on In re Kauffman Mutual Fund Actions · United States v. Giordano · United States v. Tortorello · United States v. Armocida · United States v. James
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'Merely because a normal investigative technique is theoretically possible, it does not follow that it is likely. What [the exhaustion] provision envisions is that the showing be tested in a practical and common sense fashion [citation omitted].’” Calhoun, supra at 374 . Consequently, the State”
3 later decisions quote this exact passage · from the majority“"A full and complete statement as to whether or not other investigative procedures have been tried and failed or why they reasonably appear to be unlikely to succeed if tried or to be too dangerous.. . .””
2 later decisions quote this exact passage · from the majority““Courts are not free to infer from the mere presentation of an application or petition, supported by an affidavit, that normal investigative procedure will not work. There must be specific compliance with 18 U.S.C. § 2518 . The affidavit must demonstrate to the issuing judge that normal investigative measures have been tried and failed, or they are unlikely to be successful under the circumstances, or that their use is too perilous to the investigators. That a prior affidavit for another time and place so demonstrates, even when incorporated by reference, is not compliance with the strict requirements of the Act.” 34 Md. App. at 376-77 , 367 A. 2d at 46 . (Original emphasis.)”
1 later decision quote this exact passage · from the majority
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.