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← 85 MDAPP 523 - Brown v. State

Brown v. State’s Empirical Analysis

1991

Citation profile

6
cited by 6 later decisions
1
states following
December 1992
most recently cited

6 state decisions

Relationships

Relies on Mills v. Maryland · Dorsey v. State · People v. Haston · Ross v. State · United States v. Long

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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““[rnjoreover, ... Jennings concerned] statements made to State agents during the commission of the crime on trial, and not statements made during subsequent crimes. “The case sub judice does not fall within the limited ... Jennings exclusion [ ]. The plain reading of Md.Rule 4-263(b)(2) requires the disclosure of ‘all statements’ made to State agents. ... Jennings ... excluded the ‘obvious’ statements in any illegal drug sale, the verbal acts necessary to effect a transaction. In ... Jennings the statements were negotiations for the purchase of illegal drugs. Further, the excluded verbal acts formed the crime for which the defendant was standing trial. To ensure that the accused will have the opportunity to prepare a defense free from unfair surprise, we will strictly construe every limitation upon Md.Rule 4-263(b)(2). Only those statements that pertain directly to verbal acts necessary to effect the commission of the crime for which the defendant is accused are excluded from Md.Rule 4-263(b)(2). Appellant’s statement was an extraneous remark made at the conclusion of a sale of cocaine conducted almost three weeks after the alleged transaction for which the defendant was on trial. It was discoverable under Md.Rule 4-263(b)(2), and should have been produced in response to the defendant’s request.””
    1 later decision quote this exact passage
  2. “Q: Now, did he hand the drugs to you or did he hand the drugs to the Cl [confidential informant]? A: No, he handed the drugs to the Cl. Q: What did Mr. Brown say to the Cl? A: He told the Cl the next time for him to do a deal by himself. Q: Did Mr. Brown then have occasion to say anything to you? A: Yes. He told me that it’s not that—he said exactly, “It’s not that you’re not okay, I just don’t deal with anybody new.””
    1 later decision 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.