39 Md. App. 133 - Baker v. State’s Empirical Analysis
1978
Citation profile
14 state decisions
How this case has been cited
Cited by 17 later decisions — most recently November 2016
14 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 Wong Sun v. United States · Katz v. United States · Mapp v. Ohio · Aguilar v. Texas · Gerstein v. Pugh
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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The Wong Sun Court went further and stated: ‘We need not hold that all evidence is “fruit of the poisonous tree” simply because it would not have come to light but for the illegal actions of the police. Rather, the more apt question in such a case is “whether, granting establishment of the primary illegality, the evidence to which instant objection is made has been come at by exploitation of that illegality or instead by means sufficiently distinguishable to be purged of the primary taint.” ’ (Citation omitted.) Id, at 140.”
1 later decision quote this exact passage · from the majority““1) where the evidence sought to be introduced has an independent source, or 2) the evidence would inevitably have been discovered, or 3) where ‘the connection between the lawless conduct of the police and the discovery of the challenged evidence has become so attenuated as to dissipate the taint’ (quoting Baker v. State, 39 Md.App.133, 140, 383 A.2d 698 (1978)).””
1 later decision quote this exact passage · from the majoritye.g. Zimmerman v. State““Appellant, however, contends that his illegal arrest precludes any identification of him, so that he should in no way be connected with the offense and must be freed. The argument advanced by appellant may be styled as the ‘but for’ approach. ‘But for’ the illegal arrest he would not have been caught and, ergo, could not have been identified as the culprit.””
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.