8 Md. App. 439 - Frasher v. State’s Empirical Analysis
1970
Citation profile
3 federal appellate · 48 state decisions
How this case has been cited
Cited by 52 later decisions — most recently July 2022 · most notably Sigma Reproductive Health Center v. State (1983), 164 Md. App. 95 - Marquardt v. State (2005)
3 federal appellate · 48 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 5 Md. App. 450 - Williams v. State · Breeding v. State · Bowen v. State · 8 Md. App. 355 - Simmons v. State · Worthington 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 52 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t is a defense as to all crimes except taking the life of an innocent person that the defendant acted under a compelling force of coercion or duress.”
5 later decisions quote this exact passage · from the majority“In accord with the purpose of a bail bond and to make control of the principal by the surety effective, the surety has been regarded as subrogated to the rights and means possessed by the State for that purpose and to be entitled to seize his principal for the purpose of surrendering him in discharge of the surety’s liability, and, to the extent necessary to accomplish this, the surety may restrain him of his liberty. Although the surety has the right to requisition official help to take the principal into custody, for the purpose of surrendering him in exoneration of his liability, the surety has also been regarded as entitled to take the principal into custody himself, and at common law no process was necessary to authorize the arrest of the principal by his bail. On the ground that the right to take the principal into custody and surrender him results from the nature of the undertaking by the bail, the rule permitting arrest without process has been applied to the right to arrest the principal in another state.”
4 later decisions quote this exact passage · from the majority“[i]n order to constitute a defense, the duress by another person on the defendant must be present, imminent, and impending, and of such a nature as to induce well grounded apprehension of death or serious bodily injury if the act is not done. It must be of such a character as to leave no opportunity to the accused for escape. Mere fear or threat by another is not sufficient nor is a threat of violence at some prior time. The defense cannot be raised if the apprehended harm is only that of property damage or future but not present personal injury.”
4 later decisions 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.