49 Md. App. 355 - State v. Hunt’s Empirical Analysis
1981
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently January 2008
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 Simmons v. State · State v. Bailey · Cumberland Glass Manufacturing Co. v. DeWitt · Leon v. State · State v. Warren
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.
“The rationale for the rule forbidding duplicity or “the joinder of two or more distinct and separate offenses in the same count” was succinctly set forth by the Court of Appeals in State v. Warren, [ 77 Md. 121, 122 , 26 A. 500 (1893) ] where it said: “The object of all pleading, civil and criminal, is to present a single issue in regard to the same subject matter, and it would be against this fundamental rule to permit two or more distinct offenses to be joined in the same count.” (Emphasis supplied.)”
1 later decision quote this exact passage · from the majoritye.g. Albrecht v. State“In its Report, the joint subcommittee noted: “The paragraph on aggregation was inserted on the basis that a person who steals property at different times from several persons and places as part of a continuing scheme has engaged in activity which is just as reprehensible as a person who steals an equal amount from a single person and place at one time. It is a marked departure from the common law which requires that the property be stolen from a single person at a single time and place.” 2”
1 later decision quote this exact passage · from the majoritye.g. Kelley v. State““The charging documents in question allege a series of thefts but fail to allege that they were committed pursuant to one scheme or continuing course of conduct. Therein lies the problem. Absent such an allegation, the charging docu ments merely allege separate and distinct crimes in a single count which makes them duplicitous.””
1 later decision quote this exact passage · from the majoritye.g. Kelley 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.