Cox v. State’s Empirical Analysis

Citation profile

27 state decisions

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

1. “[T]he State did not use the words “intervening circumstance or cause.” Its basic premise, however, was the same at the suppression hearing and on appeal — that Petitioner was arrested pursuant to an arrest warrant; the burden was on the defense to show that the arrest warrant was invalid. In addition, the State relied on Gibson, 138 Md.App. 399 , 771 A.2d 536 , which involved an explanation of the fruit of the poisonous tree doctrine and the applicable process that is employed to dissipate or attenuate the taint of the primary illegality. We hold that the issue as to the legality of the arrest was plainly preserved, for appellate review, even though the State did not use the “magic words,” “dissipate” or “attenuate,” to explain why “the initial encounter [did] not matter” — because of the intervening event, i.e., the discovery of an outstanding warrant and an arrest pursuant thereto. Thus, we are satisfied that the issue was put forth at the trial level and the contention that there was an intervening circumstance is properly before us.”

   2 later decisions quote this exact passage
   e.g. Pettigrew v. State · 173 Md. App. 414 - State v. Mason

2. “'the purpose and flagrancy of the official misconduct.'”

   2 later decisions quote this exact passage
   e.g. 238 Md. App. 87 - Thornton v. State · 230 Md. App. 640 - State v. Sizer

3. ““We shall hold that the police officer’s discovery of an outstanding warrant for Petitioner’s arrest and Petitioner’s arrest pursuant thereto represents an intervening circumstance sufficient to attenuate the taint of what appears to be an illegal stop.””

   1 later decision quote this exact passage
   e.g. 230 Md. App. 640 - State v. Sizer