34 Md. App. 454 - Covington v. State’s Empirical Analysis
1977
Citation profile
21 state decisions
How this case has been cited
Cited by 21 later decisions — most recently January 2020
21 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 Johnson v. Zerbst · Gideon v. Wainwright · Carnley v. Cochran · Herring v. New York · Brookhart v. Janis
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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The plea of not guilty, accompanied by an ‘Agreed Statement of Facts’, is a peculiar animal. As was succinctly stated in Barnes v. State, 31 Md. App. 25, 35 , 354 A. 2d 499, 505 (1976), ‘Under an agreed statement of facts both State and the defense agree as to the ultimate facts. Then the facts are not in dispute, and there can be, by definition, no factual conflict. The trier of fact is not called upon to determine the facts as the agreement is to the truth of the ultimate facts themselves. There is no fact-finding function left to perform. To render judgment, the court simply applies the law to the facts agreed upon. If there is agreement as to the facts, there is no dispute [.]’ ” Id. at 455.”
3 later decisions quote this exact passage · from the majority““Some cases may appear to the trial judge to be simple — open and shut — at the close of the evidence. And surely in many such cases a closing argument will, in the words of Mr. Justice Jackson, be ‘likely to leave [a] judge just where it found him.’ But just as surely, .there will be cases where closing argument may correct a premature misjudgment and avoid an otherwise erroneous verdict. And there is no certain way for a trial judge to identify accurately which cases these will be, until the judge has heard the closing summation of counsel.””
1 later decision quote this exact passage · from the majoritye.g. Covington v. State““I will only proceed in this case if the defendant forgoes his right to testify. In other words, he has to agree to the facts and not testify to the contrary. Anything he wants to say in mitigation he can say after and if a guilty finding is made.””
1 later decision quote this exact passage · from the majoritye.g. Covington v. State
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.