Maddox v. State’s Empirical Analysis

Citation profile

107 state decisions

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 107 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In Maddox , ... an undercover officer bought methamphetamine from the defendant who was sitting in his truck and who handed the contraband to a cohort to give to the officer. The defendant was immediately arrested and a rifle was seized from the floorboard of the pickup truck in which he had been seated. This Court held that the rifle was admissible because it “was shown to have been directly connected with, and contemporaneous to, and inseparable from the arrest of the appellant.” This language, taken by itself, flies in the face of Hemande£ 4 ] and the general relevancy requirement for extraneous matters. However, although the majority in Maddox does not so state, the arguable implication from the facts and from the concurring opinion is that the rifle was admissible to show the context of the offense because during the drug transaction the defendant possessed a weapon.... Where possession of a weapon is involved when an offense is committed, such fact is usually relevant as a circumstance of the offense because arguably the weapon is intended by the defendant to be used, exhibited, or simply possessed for protection or threat during the offense. To interpret the statement in Maddox literally would mean that anything recovered during an arrest would be admissible, regardless of its lack of connection to the charged offense. ... This is certainly not permissible under the law governing admission of extraneous matters, [cite omitted] When an arrest is made during or immediate”

   1 later decision quote this exact passage · from the majority
   e.g. Christopher v. State

2. ““[EJvidence of the context of the offense is almost always admissible under the reasoning that events do not occur in a vacuum and the jury has a right to have the offense placed in its proper setting so that all evidence may be realistically evaluated. See Maddox v. State, 682 S.W.2d 563 (Tex.Cr.App.1985) (Clinton, J., concurring); and Taylor v. State, 420 S.W.2d 601 (Tex.Cr.App.1967). Rarely will the prejudicial value render inadmissible any evidence that is [in] context of the offense.” Mann v. State, 718 S.W.2d 741, 743-744 (Tex.Cr.App.1986). (Emphasis supplied.)”

   1 later decision quote this exact passage · from the concurrence
   e.g. Wilkerson v. State

3. “The articles in question were found in appellant’s possession at the time of the commission of the offense and of the arrest. They were circumstances surrounding the offense and the arrest, and were relevant not only to guilt, but also to the issues of punishment and probation. No clear abuse of the trial court’s discretion is shown.”

   1 later decision quote this exact passage
   e.g. Paz v. State