Howard v. State’s Empirical Analysis
1991
Citation profile
13 state decisions
How this case has been cited
Cited by 13 later decisions — most recently March 2026
13 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 United States v. Hooks · Spuehler v. State · Bowen v. State · Staples v. State · Barnes 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]e hold that in order to support a conviction ... for maintaining a residence or other structure or place used for keeping controlled substances, the evidence must show that one of the purposes for maintaining the structure was the keeping of the controlled substance; thus, the mere possession of limited quantities of a controlled substance within the residence of structure is insufficient to support a conviction[ ]. [We further] hold that in order to support a conviction under this statute for maintaining a residence or other structure or place used for selling controlled substances, the evidence must be sufficient to support a finding of more than a single, isolated instance of the proscribed activity ....”
2 later decisions quote this exact passagee.g. State v. Mitchell · Watts v. State“A conviction of the crime of maintaining a place where controlled dangerous substances are kept requires that the activity giving rise to the charge must be more than a single, isolated activity. Rather, the term implies an element of some degree of habitualness. A conviction of the crime of maintaining a place where controlled dangerous substances are kept requires thai a substantial purpose, and not necessarily the sole purpose, of the residence is for the keeping or selling of controlled dangerous substances ... in violation of the law. The mere possession of limited quantities of a controlled dangerous substance by the person keeping or maintaining the residence for that person's personal use within that residence is insufficient to support a conviction of the crime of maintaining a place where controlled dangerous substances are kept. (emphasis added).”
1 later decision quote this exact passagee.g. Watts v. State“A. It shall be unlawful for any person: 6. To keep or maintain any ... dwelling house ..., which is resorted to by persons using controlled dangerous substances in violation of this act for the purpose of using such substances, or which is used for the keeping or selling of the same in violation of this act.”
1 later decision quote this exact passagee.g. Meeks 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.