77 Md. App. 537 - Allen v. State’s Empirical Analysis
1989
Citation profile
24 state decisions
How this case has been cited
Cited by 24 later decisions — most recently April 2013
24 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 Johnson v. Zerbst · Johnson v. Louisiana · Apodaca v. Oregon · Securities & Exchange Commission v. Medical Committee for Human Rights · United States v. Gipson
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The court shall notify the defendant and the State’s Attorney of the receipt of any communication from the jury pertaining to the action before responding to the communication. All such communications between the court and the jury shall be on the record in open court or shall be in writing and filed in the action.”
8 later decisions quote this exact passagee.g. Taylor v. State · Graham v. State““[wjhile the rule expressly requires notice to the parties of any communication from the jury, its very spirit is to provide an opportunity for input in designing an appropriate response to each question in order to assure fairness and avoid error.””
2 later decisions quote this exact passagee.g. Graham v. State · Stewart v. State“We realize that if the trial judge had disclosed the entire contents of [the note] there would have been no possibility of waiver. We think, however, that any gain in the speedy and efficient administration of justice, i.e., avoiding a retrial, is outweighed by a criminal defendant’s interest in being able to assess intelligently his chances before waiving his right to a unanimous verdict. Therefore, we establish a "bright-line” rule which requires a trial judge to read the contents of any jury communication to both the State and the defense before allowing the defendant to accept a majority verdict. A bright-line rule in cases such as this will avoid the uncertainties which would arise were we to hold merely that the substance of jury communications be revealed. If this means that no waiver is possible where the jury has revealed its position, so be it.”
1 later decision quote this exact passagee.g. Claybourne v. State
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.