5 Md. App. 691 - Palmer v. State’s Empirical Analysis
1969
Citation profile
33 state decisions
How this case has been cited
Cited by 37 later decisions (2 by the Supreme Court) — most recently May 1984 · most notably Kirby v. Illinois (1972), 1 Cal. 3d 335 - People v. Fowler (1969)
33 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 Chapman v. State of California · Wong Sun v. United States · Johnson v. Zerbst · United States v. Wade · Stovall v. Denno
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““We think it necessarily follows that the rules of Wade and Gilbert apply also to a lineup conducted before indictment and to other pretrial confrontations within the meaning of Tyler. 1 We again note that in Stovall , at 300, the Court said that Wade and Gilbert affect ‘ * * * all future cases which involve confrontations for identification purposes conducted in the absence of counsel * * (emphasis supplied). It did not limit their affect to ‘post-indictment lineups.’ . . . .” Id. 5 Md. App. at 696 , 249 A. 2d at 486 .”
1 later decision quote this exact passage · from the majority““Independent of any right to counsel claim, a confrontation may be ‘so unnecessarily suggestive and conducive to irreparable mistaken identification’ as to be a denial of due process of law. ‘However, a claimed violation of due process of law in the conduct of a confrontation depends on the totality of the circumstances surrounding it * * ””
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.