Fields v. State’s Empirical Analysis
2006
Citation profile
14
cited by 14 later decisions
1
states following
April 2017
most recently cited
14 state decisions
Relationships
Relies on Dorsey v. State · Bernadyn v. State · State v. Logan · Stoddard v. State · Kedzierski v. State
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“convictions stem[med] from the shootings of three young men at a bowling alley in Clinton, Maryland, shortly after midnight on May 17, 2003. The three men were among a group of about [fifteen] employees of a nearby supermarket who were enjoying a night out at the bowling alley. Tyneal Bussey was killed by a gunshot wound to the chest. Early Eborn was shot in the abdomen and Rozier Davis was shot in the arm. The State’s evidence showed that, while at the bowling alley on the night in question, [Fields] became involved in a dispute with Bussey and asked Bussey to step outside. [Fields] exited the bowling alley and went outside to the parking lot as Bussey ... headed for the doorway..... A crowd gathered by the doorway of the bowling alley. Several witnesses testified that a white car was parked outside, and that [Fields] was standing beside the car, holding a rifle. When Bussey reached the doorway, [Fields] opened fire, killing Bussey and injuring Davis and Eborn..... There was also evidence introduced by the State that [Fields, whose first name is Saturio,] went by the nickname “Sat Dogg.” Detective Ismael Canales, a member of the homicide unit of the Prince George’s County Police Department, was among the officers who responded to a report of shootings at the bowling alley. Once inside, he observed that there was a television monitor at each bowling lane, and the names and scores of the bowlers at that lane were displayed on the screen. ....... Detective Canales proceeded to ”
1 later decision quote this exact passage“The prosecutor did not attempt to use the evidence of the words “Sat Dogg” on the screen at the bowling alley to show that a known declarant believed [Fields] was present there, had reason to accurately hold that belief, and therefore was impliedly asserting that factual proposition by entering his nickname on the screen. [T]he probative value of the evidence that [Fields’s] name was on the television screen did not depend upon the belief of the person who typed the name on the screen, or upon the accuracy of that person’s belief. The prosecutor did not argue that the person who entered the name “Sat Dogg” on the screen only would have done so if he or she believed that [Fields] was present in the bowling alley. Indeed, there was no evidence about that person’s belief, because the person was not identified. The prosecutor argued only that the crime scene included a bowling lane with the name “Sat Dogg” written above it. [Fields’s] name on the television screen in the bowling alley was not an implied assertion of the factual proposition that [Fields] was present at the bowling alley[.] Because the evidence was not an “assertion,” under Rule 5-801(a), it was not a “statement” under that subsection and hence was not hearsay under Rule 5-801(c). It was admissible non-hearsay evidence. Accordingly, the trial court’s evidentiary ruling was not in error.”
1 later decision quote this exact passage“We need not determine whether the testimony of Detective Canales was inadmissible based on Bemadyn, or even if the evidence is distinguishable, because even if it was hearsay and not admissible, any error was harmless beyond a reasonable doubt.”
1 later decision quote this exact passage
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.