51 Md. App. 668 - Lett v. State’s Empirical Analysis
1982
Citation profile
2 federal appellate · 27 state decisions
How this case has been cited
Cited by 29 later decisions — most recently January 2016 · most notably State v. Ledbetter (1997), 92 Md. App. 137 - Markey v. Wolf (1992)
2 federal appellate · 27 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 Wong Sun v. United States · Coolidge v. New Hampshire · Dayton Board of Education v. Brinkman · Forsham v. Harris · National Theatres Corp. v. Bertha Building Corp.
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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(c) Third conviction of crime of violence.—Any person who (1) has been convicted on two separate, occasions of a crime of violence where the convictions do not arise from a single incident, and (2) has served at least one term of confinement in a correctional institution as a result of a conviction of a crime of violence, shall be sentenced, on being convicted a third time of a crime of violence, to imprisonment for the term allowed by law, but, in any event, not less than 25 years. Neither the sentence nor any part of it may be suspended, and the person shall not be eligible for parole except in accordance with the provisions of Article 31B, § 11. A separate occasion shall be considered one in which the second or succeeding offense is committed after there has been a charging document filed for the preceding occasion.””
1 later decision quote this exact passage · from the majority““In addition, we note that unless a defendant’s two prior convictions occur on ‘two separate occasions’ the predicates of § 643B(c) have not been satisfied. This is true even when the two prior convictions arise from totally separate incidents. Thus, a defendant who is convicted at one trial of several crimes of violence may escape the mandatory sentence of § 643B(c). In contrast, however, the mandatory life sentence provision, § 643B(b), requires only ‘three separate convictions.’ It does not require that the convictions be obtained on separate occasions. These discrepancies and variations are indicative of the need for legislative clarification of the statutory enactment.””
1 later decision quote this exact passage · from the majority“There are two facets to the jurisdiction of a court-jurisdiction over the subject matter and venue. With respect to the subject matter, within its county, a circuit court of this State has full common law jurisdiction in all criminal cases committed in Maryland except where limited by law. Maryland Code (1974) Courts and Judicial Proceedings Article § 1-501. Venue, however, is the place of trial, or where a criminal trial may properly occur.”
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.