54 Md. App. 486 - Samuels v. State’s Empirical Analysis
1983
Citation profile
22 state decisions
How this case has been cited
Cited by 22 later decisions — most recently September 2011
22 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 · Ross v. State · Watson v. State · Brewer v. Mele · McKnight 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Maryland continues to adhere to the rule that a conviction may not rest upon the uncorroborated testimony of an accomplice. Turner v. State, 294 Md. 640 , 452 A.2d 416 (1982); Brown v. State, 281 Md. 241 , 378 A.2d 1104 (1977). The policy underlying the rule was stated in Watson v. State, 208 Md. 210, 217 , 117 A.2d 549 (1955): The reason for the ruling requiring the testimony of an accomplice to be corroborated is that it is the testimony of a person admittedly contaminated with guilt, who admits his participation in the crime for which he particularly blames the defendant, and it should be regarded with great suspicion and caution, because otherwise the life or liberty of an innocent person might be taken away by a witness who makes the accusation either to gratify his malice or to shield himself from punishment, or in the hope of receiving clemency by turning State’s evidence. While the corroboration evidence may be slight and need not, in itself, be sufficient to convict, it must relate to material facts which would either: 1) identify the accused with the perpetrators of the crime or 2) show the participation of the accused in the crime itself. If the corroborative evidence tends to establish either of these matters, the trier of fact may give credit to the testimony of the accomplice even with respect to matters which are not corroborated. Brown v. State, supra. With respect to corroborative evidence tending “to identify the defendant with the perpetrators of the crime,”
2 later decisions quote this exact passage · from the majority“Unexplained possession of recently stolen goods gives rise to an inference that the possessor is the thief; if the theft occurred as part of a burglary or robbery, the inference is that the possessor is the burglar or robber.”
2 later decisions quote this exact passage · from the majority“1) [The] proximity between the defendant and the contraband, 2) the fact that the contraband was within the view or otherwise within the knowledge of the defendant, 3) ownership or some possessory right in the premises or the automobile in which the contraband is found, or 4) the presence of circumstances from which a reasonable inference could be drawn that the defendant was participating with others in the mutual use and enjoyment of the contraband.”
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.