79 Md. App. 241 - Best v. State’s Empirical Analysis
1989
Citation profile
67 state decisions
How this case has been cited
Cited by 68 later decisions — most recently December 2022 · most notably Bernard v. United States (1990), 129 Md. App. 221 - Rosenberg v. State (1999)
67 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
Applies 21 U.S.C. § 812 (§ 202 of the Controlled Substances Act)
Relies on Mullaney v. Wilbur · 28 Md. App. 640 - Evans v. State · State v. Evans · Breeding v. State · United States v. Luschen
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 68 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[ 0]ur ultimate holding as to the admissibility of the evidence does not depend upon such technical compliance [with 10-1003]. ... A rule—any rule—does not exist for its own sake alone but only to serve an undergirding purpose. When in our judgment that undergirding purpose has clearly been served, we are not about to worry over whether there has been blind and literal obedience to the rule in the tradition of a Prussian drillmaster. The purpose of the rule under consideration is to guarantee the integrity of the physical evidence. ❖ * * That the purpose of [enacting §§ 10-1001, 10-1002, 10-1003] was to facilitate the admission of evidence and not to require the exclusion of evidence was made clear by the preamble to the Act, which provided that it was being enacted “[f]or the purpose of providing for the admission of written reports of analyses of, and statements of the chain of custody of, suspected controlled dangerous substances as prima facie evidence and for exceptions thereto.””
3 later decisions quote this exact passage“means: (i) The seizing officer; (ii) The packaging officer, if the packaging officer is not also the seizing officer; and (iii) The chemist or other person who actually touched the substance and not merely the outer sealed package in which the substance was placed by the law enforcement agency before or during the analysis of the substance; and (2)”
3 later decisions quote this exact passage“(a)(1) In a criminal proceeding, the prosecution shall, upon written demand of a defendant filed in the proceedings at least 5 days prior to a trial in the proceeding, require the presence of the chemist, analyst, or any person in the chain of custody as a prosecution witness. (2) The provisions of §§ 10-1001 and 10-1002 of this part concerning prima facie evidence do not apply to the testimony of that witness. (3) The provisions of §§ 10-1001 and 10-1002 of this part are applicable in a criminal proceeding only when a copy of the report or statement to be introduced is mailed, delivered, or made available to counsel for the defendant or to the defendant personally when the defendant is not represented by counsel, at least 10 days prior to the introduction of the report or statement at trial. (b) Nothing contained in this part shall prevent the defendant from summoning a witness mentioned in this part as a witness for the defense.”
2 later decisions quote this exact passage
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.