51 Md. App. 271 - Cox v. State’s Empirical Analysis
1982
Citation profile
30 state decisions
How this case has been cited
Cited by 37 later decisions — most recently October 2023 · most notably State v. Cox (1983), Clinebell v. Commonwealth (1988)
30 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 · Kotteakos v. United States · Davis v. Alaska · Giles v. State of Maryland · Dorsey 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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[DEFENSE COUNSEL]: I think I should proffer in this fashion, I have information that the witness made a criminal charge against this Vrhovac of assault on her. And then subsequent, during the course of the trial admitted that she did not tell the truth, that it was not an assault on her. And that he was, as a result of her recanting her statement, found not guilty. MR. LEVITZ: How is that relevant to this trial? MR. KAHN: Credibility. THE COURT: If you have a whole lot of them, but just one isolated instance. MR. KAHN: Testimony, false testimony that was recanted. MR. LEYITZ: From.what you have indicated she told the truth in court. MR. KAHN: No. She first came into court and said that he did commit the assault, and then on cross-examination the information I have is that she then recanted it. MR. LEVITZ: Judge, this is— THE COURT: I think it’s an independent matter. And if it were more than one, but one isolated instance I don’t think it’s relevant to this, so I will sustain the objection.”
1 later decision quote this exact passage · from the dissente.g. State v. Cox“The determination of whether there has been an abuse of discretion necessarily requires consideration of the particular circumstances bearing upon each individual case. Clearly, the absolute preclusion of cross-examination pertaining to a witness’s motive for testifying would be an abuse of discretion, but beyond that we must look to such factors as the scope of interrogation permitted, how relevant the particular inquiry is to bias or motive, and whether the defendant has been prejudiced by the court’s ruling.”
1 later decision quote this exact passage · from the dissent“The 'discretion’ then, between the defendant’s right to discredit testimony and the trial judge’s duty to protect a witness is solely one of relevance of the questions to the witness’s credibility. The relevancy test at this juncture does not regard the elucidation of one of the main issues at trial, it is whether the answer elicited will be a useful aid to the court or jury in appraising the credibility (not necessarily the veracity) of the witness and in assessing the probative value of his direct testimony.”
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.