8 Md. App. 134 - Franklin v. State’s Empirical Analysis
1969
Citation profile
3 federal appellate · 54 state decisions
How this case has been cited
Cited by 61 later decisions — most recently June 2020 · most notably United States v. Blackston (1991), 105 Wash. 2d 120 - State v. Hornaday (1986)
3 federal appellate · 54 state decisions — followed in 11 states
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 Bryant v. State · Vincent v. State · Stewart v. State · Miller v. State · 7 Md. App. 18 - Haley 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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The court noted generically that evidence showing that a person has a prohibited narcotic drug within his system, while not per se constituting possession or control ..., would tend to show circumstantially that he was in possession and/or control of the drug prior to taking it.”
2 later decisions quote this exact passage · from the majority“"The sufficiency of this independent evidence need not establish, by itself, the corpus delicti beyond a reasonable doubt, but any facts and circumstances that are substantial in nature and fortify the truth of the confession or statement are sufficient to support a conviction. The character, nature, and amount of independent proof of the corpus delicti need not, of itself, be full and positive; it may be circumstantial in nature when direct evidence is not available. In short, the existence of such independent proof is to be determined largely by the circumstances of each particular case. And it has been held that testimony in proof of the corpus delicti is sufficient if it establishes facts that are consistent with the commission of a crime, although they may at the same time indicate, or be consistent with, a noncriminal causation.” 8 Md. App. at 140 . (citations omitted).”
1 later decision quote this exact passage · from the majority“[defendant’s] statement “that he had taken an overdose of heroin intravenously,” after which he had “passed out,” justifies not only the inference that prior to taking such drug, he necessarily was in possession of it, but also the inference, absent affirmative contradictory evidence, that the drug was self-administered, or administered by another at his direction (thus placing him in constructive possession of the drug). That [defendant’s] physical condition was consistent with his having taken an overdose of heroin is clear from [the hospital physician’s] testimony.”
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.