8 Md. App. 91 - Tipton v. State’s Empirical Analysis
1969
Citation profile
21 state decisions
How this case has been cited
Cited by 21 later decisions — most recently September 1994
21 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 Benton v. Maryland · Fong Foo v. United States · Weiler v. United States · Hammer v. United States · United States v. Wood
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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Subornation of perjury consists of all the elements enumerated in the crime of perjury (committed by the witness alleged to be suborned), and one additional element, that the accused induced, persuaded and instigated the suborned witness to commit the crime of perjury. This additional fact (procurement of the witness) does not require proof by more than one witness, State v. Ruskin, 117 Ohio St. 426 , 159 N. E. 568 , 56 A. L. R. 403. The attempt to suborn a prospective witness to commit perjury (the instant indictment) is a common law crime separate and dis tinct from subornation of perjury. Appellant is correct in stating that in subornation of perjury there must be proof of actual perjury committed by the suborned witness. But as to attempts to suborn one to commit perjury it is unnecessary that the person suborned did testify falsely, or indeed did testify at all. The offense is made out whenever the accused instigates and procures the agreement of the prospective witness to testify falsely. This is true even if thereafter the prospective witness fails to go through with the bargain and refuses to give evidence. It is, of course, a necessary element of the crime that both the accused and the person to be suborned knew that the testimony sought was false, material, and to be used in actual or prospective litigation. [ 54 A. 2d at 707-708 ]”
1 later decision quote this exact passage · from the majoritye.g. State v. Williams“". . . This State permits the testimony of one witness to support convictions for the most serious crimes, e.g., murder, Rasnick v. State, 7 Md. App. 564 , 256 A.2d 543 ; rape, Charles v. State, 4 Md. App. 110, 241 A.2d 435 ; and armed robbery, Carroll v. State, 3 Md. App. 50 , 237 A.2d 535 . In the absence of binding authority, we perceive no reason to apply the two-witness rule to any part of attempted subornation of peijury under the facts of the case at bar.””
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.