49 Md. App. 467 - Lemons v. State’s Empirical Analysis
1981
Citation profile
3 federal appellate · 36 state decisions
How this case has been cited
Cited by 39 later decisions — most recently May 2016 · most notably State v. Parker (1985), Government of the Virgin Islands v. Harris (1991)
3 federal appellate · 36 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 Jackson v. Virginia · In the Matter of Samuel Winship · Ross v. State · 37 Cal. 2d 614 - People v. Cullen · Hadder 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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In every Maryland case reported thus far involving the corroboration rule in the context of a homicide, the victim’s body had been recovered and there was other independent evidence, either direct or circumstantial, to suggest that the death was not the result of accident or suicide. See, e.g., Miller v. State, 251 Md. 362 , 247 A.2d 530 (1968); Hadder [v. State], supra [ 238 Md. 341 , 209 A.2d 70 (1965) ]; Jones [v. State], supra [ 188 Md. 263 , 52 A.2d 484 (1947) ]. This, of course, does not imply that the inability to produce a body is an insuperable obstacle, in itself, to the obtention and sustention of a murder conviction. This Court, as well as the Court of Appeals, has repeatedly said that the independent evidence of the corpus delicti “may be circumstantial in nature when direct evidence is not available,” Miller, supra at 382 [ 247 A.2d 530 ]; Franklin v. State, 8 Md.App. [134,] at 140, [ 258 A.2d 767 (1969) ], and there is no reason to believe that this statement does not apply to the fact of death with the same force as it does to the criminal causation.... Nevertheless, it is clear from these cases that there must be independent evidence, at least circumstantial in nature, that relates to both elements of the corpus delicti Thus, the problem in the present case is not that the State failed to produce [the victim’s] body, for if she was, in fact, murdered as [the defendant] described, there would be no body to produce; rather, the problem here is that the State fa”
3 later decisions quote this exact passage · from the majority““In a homicide case the proof of the corpus delecti is sufficient if it establishes the fact that the person for whose death the prosecution was instituted is dead, and that the death occurred under circumstances which indicate that it was caused criminally by someone.””
2 later decisions quote this exact passage · from the majority“The standard for our review of the sufficiency of the evidence is whether, after reviewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. We defer to the fact finder’s opportunity to assess the credibility of witnesses, weigh the evidence, and resolve conflicts in the evidenced] While we do not re-weigh the evidence, we do determine whether the verdict was supported by sufficient evidence, direct or cir cumstantial, which could convince a rational trier of fact of the defendant’s guilt of the offenses charged beyond a reasonable doubt. The same review standard applies to all criminal cases, including those resting upon circumstantial evidence, since, generally, proof of guilt based in whole or in part on circumstantial evidence is no different from proof of guilt based on direct eyewitness accounts. Circumstantial evidence is entirely sufficient to support a conviction, provided the circumstances support rational inferences from which the trier of fact could be convinced beyond a reasonable doubt of the guilt of the accused. Furthermore, the fact finder, not the appellate court, resolves conflicting evidentiary inferences. The primary appellate function in respect to evidentiary inferences is to determine whether the trial court made reasonable, ie., rational, inferences from extant facts. Generally, if there are evidentiary facts sufficiently supporting th”
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.