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← 99 Md. App. 60 - Betz v. State

99 Md. App. 60 - Betz v. State’s Empirical Analysis

1994

Citation profile

28
cited by 28 later decisions
1
states following
December 2016
most recently cited

26 state decisions

How this case has been cited

Cited by 28 later decisions — most recently December 2016 · most notably 114 Md. App. 641 - Naughton v. Bankier (1997), Dorsey v. Nold (2001)

26 state decisions

160199420002010decided

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 State v. Roll and Scholl · Duemling v. Fort Wayne Community Concerts, Inc. · Winter v. Crowley · 12 Md. App. 346 - Goldsborough v. State · Mitchell 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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Although judicial anger is understandable, a judge should not let his displeasure with litigants, witnesses, or lawyers unduly affect his conduct in the courtroom---- In this case, [the] Judge ... allowed his anger to get the best of him; as a result, he adopted an unjudicial attitude toward appellant [and his counsel]. We think it is important to repeat the following admonition of this Court in Betz v. State, 99 Md.App. 60 , 635 A.2d 77 (1994): Many judges have experienced aggravating—sometimes even defiant—conduct on the part of lawyers and others (just as many lawyers, and others, have experienced aggravating conduct on the part of judges), and, in the press of attempting to move dockets and resolve cases fairly and efficiently, the experience can cause instant irritation. Judges, too, are human and have human emotions; they get angry, often for good reason. But, unlike other people, judges have the sovereign power to punish, to deprive persons of their liberty and property, and that alone requires that they restrain their irritation. Punishment for contempt should never be imposed in anger, as an immediate emotionally reflexive response.”
    2 later decisions quote this exact passage
  2. “‘[I]n a narrow sense, a contempt has been defined as á despising of the authority, justice, or dignity of the court; in a more general sense, a person whose conduct tends to bring the authority and administration of the law into disrespect or disregard, interferes with or prejudices parties or their witnesses during litigation, or otherwise tends to impede, embarrass, or obstruct the court in the discharge of its duties, has committed a contempt.’”
    2 later decisions quote this exact passage
  3. “[The circuit court] knew only that the statement ] had not been submitted and exchanged as required by [the] order____[It] did not know, because [it] had not asked, why [Betz] had not submitted and exchanged her statement. The “why,” however was an important element that needed to be considered before finding [ ] contempt, for it went to her intent.”
    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.