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5 Maryland opinions name it 1 courts 1988–2021 1 in the last five years
The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
United States v. Vincent Gigante, Also Known as \Chingreen2 sentences2021But see United States v. Gigante, 166 F.3d 75, 81 (2nd Cir. 1999) (declining to require a finding of Craig-based necessity before allowing witness to testify via two-way video platform). 10 Like most other jurisdictions that have addressed this issue, Maryland courts have allowed two-way video testimony only when the Craig standard is satisfied. 2021But see United States v. Gigante, 166 F.3d 75, 81 (2nd Cir. 1999) (declining to require a finding of Craig-based necessity before allowing witness to testify via two-way video platform). 10 Like most other jurisdictions that have addressed this issue, Maryland courts have allowed two-way video testimony only when the Craig standard is satisfied. | 2 | 3 |
State of Iowa v. Zachariah J. Rogersongreen2 sentences2015See, e.g., State v. Rogerson, 855 N.W.2d 495, 502-03 (2014) (cataloguing and discussing decisions from many jurisdictions and concluding that all surveyed jurisdictions, except one, applied the Craig analysis to both one-way and two-way video systems). 37 heard—is isolated from the solemn atmosphere of the courtroom and compromises human connection to emotions like fear, apprehension, or confusion. 2015See, e.g., State v. Rogerson, 855 N.W.2d 495, 502-03 (2014) (cataloguing and discussing decisions from many jurisdictions and concluding that all surveyed jurisdictions, except one, applied the Craig analysis to both one-way and two-way video systems). 37 heard—is isolated from the solemn atmosphere of the courtroom and compromises human connection to emotions like fear, apprehension, or confusion. | 2 | 3 |
United States v. Laron Cartergreen1 sentence2021See, e.g., United States v. Carter, 907 F.3d 1199, 1206 (9th Cir. 2018); United States v. Yates, 438 F.3d 1307 , 1313–17 (11th Cir. 2006); United States v. Bordeaux, 400 F.3d 548 , 554–55 (8th Cir. 2005); Iowa v. Rogerson, 855 N.W.2d 495 , 504–06 (Iowa 2014); Lipsitz v. Nevada, 442 P.3d 138 , 137–38 (Nev. 2019); cf. Wrotten v. New York, 560 U.S. 959 , 959 (2010) (Sotomayor, J., dissenting from denial of certiorari) (recognizing that whether “a two-way video that enabled the testifying witness to see and respond to those in the courtroom, and vice versa,” violated a defendant’s confrontation ri | 1 | 1 |
Horn v. Quartermangreen2 sentences2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub 2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub | 1 | 1 |
State v. Sewellgreen2 sentences2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub 2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub | 1 | 1 |
David Harrell v. Robert A. Butterworth, Attorney General for the State of Florida, Michael W. Mooregreen2 sentences2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub 2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub | 1 | 1 |
Stevens v. Stategreen2 sentences2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub 2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
United States v. Vincent Gigante, Also Known as \Chingreen2 sentences2021But see United States v. Gigante, 166 F.3d 75, 81 (2nd Cir. 1999) (declining to require a finding of Craig-based necessity before allowing witness to testify via two-way video platform). 10 Like most other jurisdictions that have addressed this issue, Maryland courts have allowed two-way video testimony only when the Craig standard is satisfied. 2021But see United States v. Gigante, 166 F.3d 75, 81 (2nd Cir. 1999) (declining to require a finding of Craig-based necessity before allowing witness to testify via two-way video platform). 10 Like most other jurisdictions that have addressed this issue, Maryland courts have allowed two-way video testimony only when the Craig standard is satisfied. | 1 | 3 |
| Case | Cited | Years |
|---|---|---|
United States v. Anita Yates
green
1 sentence2021See, e.g., United States v. Carter, 907 F.3d 1199, 1206 (9th Cir. 2018); United States v. Yates, 438 F.3d 1307 , 1313–17 (11th Cir. 2006); United States v. Bordeaux, 400 F.3d 548 , 554–55 (8th Cir. 2005); Iowa v. Rogerson, 855 N.W.2d 495 , 504–06 (Iowa 2014); Lipsitz v. Nevada, 442 P.3d 138 , 137–38 (Nev. 2019); cf. Wrotten v. New York, 560 U.S. 959 , 959 (2010) (Sotomayor, J., dissenting from denial of certiorari) (recognizing that whether “a two-way video that enabled the testifying witness to see and respond to those in the courtroom, and vice versa,” violated a defendant’s confrontation ri | 1 | 2021–2021 |
Lipsitz v. State
green
1 sentence2021See, e.g., United States v. Carter, 907 F.3d 1199, 1206 (9th Cir. 2018); United States v. Yates, 438 F.3d 1307 , 1313–17 (11th Cir. 2006); United States v. Bordeaux, 400 F.3d 548 , 554–55 (8th Cir. 2005); Iowa v. Rogerson, 855 N.W.2d 495 , 504–06 (Iowa 2014); Lipsitz v. Nevada, 442 P.3d 138 , 137–38 (Nev. 2019); cf. Wrotten v. New York, 560 U.S. 959 , 959 (2010) (Sotomayor, J., dissenting from denial of certiorari) (recognizing that whether “a two-way video that enabled the testifying witness to see and respond to those in the courtroom, and vice versa,” violated a defendant’s confrontation ri | 1 | 2021–2021 |
Pounds v. United States
green
1 sentence2021See, e.g., United States v. Carter, 907 F.3d 1199, 1206 (9th Cir. 2018); United States v. Yates, 438 F.3d 1307 , 1313–17 (11th Cir. 2006); United States v. Bordeaux, 400 F.3d 548 , 554–55 (8th Cir. 2005); Iowa v. Rogerson, 855 N.W.2d 495 , 504–06 (Iowa 2014); Lipsitz v. Nevada, 442 P.3d 138 , 137–38 (Nev. 2019); cf. Wrotten v. New York, 560 U.S. 959 , 959 (2010) (Sotomayor, J., dissenting from denial of certiorari) (recognizing that whether “a two-way video that enabled the testifying witness to see and respond to those in the courtroom, and vice versa,” violated a defendant’s confrontation ri | 1 | 2021–2021 |
United States v. Edward E. Bordeaux, Jr.
green
1 sentence2021See, e.g., United States v. Carter, 907 F.3d 1199, 1206 (9th Cir. 2018); United States v. Yates, 438 F.3d 1307 , 1313–17 (11th Cir. 2006); United States v. Bordeaux, 400 F.3d 548 , 554–55 (8th Cir. 2005); Iowa v. Rogerson, 855 N.W.2d 495 , 504–06 (Iowa 2014); Lipsitz v. Nevada, 442 P.3d 138 , 137–38 (Nev. 2019); cf. Wrotten v. New York, 560 U.S. 959 , 959 (2010) (Sotomayor, J., dissenting from denial of certiorari) (recognizing that whether “a two-way video that enabled the testifying witness to see and respond to those in the courtroom, and vice versa,” violated a defendant’s confrontation ri | 1 | 2021–2021 |
White v. State
green
2 sentences2021In White v. State, 223 Md. 2021In White v. State, 223 Md. | 1 | 2021–2021 |
Harris v. Cockrell, Director, Texas Department of Criminal Justice, Institutional Division
neutral
2 sentences2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub 2015See, e.g., Horn v. Quarterman, 508 F.3d 306, 317 (5th Cir. 2007) (concluding, on appeal from a federal habeas petition, that the state court did not unreasonably apply federal law when it permitted a terminally ill witness, whose doctor advised against travel, to testify via a two-way closed circuit television); Harrell v. Butterworth, 251 F.3d 926, 931 (11th Cir. 2001) (holding, in the context of a federal habeas petition, that the state court’s conclusion that an important public policy to excuse in-person confrontation was not contrary to federal law when “the witnesses lived beyond the sub | 1 | 2015–2015 |
Scott v. Jenkins
green
2 sentences2000A “[p]laintiff seeking to recover punitive damages must allege in detail in the complaint the facts that indicate the entertainment by defendant of evil motive or intent.” See Scott v. Jenkins, 345 Md. 21 , 690 A.2d 1000 (1997). 2000A “[p]laintiff seeking to recover punitive damages must allege in detail in the complaint the facts that indicate the entertainment by defendant of evil motive or intent.” See Scott v. Jenkins, 345 Md. 21 , 690 A.2d 1000 (1997). | 1 | 2000–2000 |
Wildermuth v. State
green
2 sentences1988In summary, we find no error. (3) Right Of Presence In addition to the confrontation issue, the Wildermuth Court considered the argument that the closed circuit television procedure authorized by § 9-102 violated the defendant’s common law and due process right of presence in that “the witness testified in a separate room, in which he was not permitted.” 310 Md. at 529 , 530 A.2d 275 . 1988In summary, we find no error. (3) Right Of Presence In addition to the confrontation issue, the Wildermuth Court considered the argument that the closed circuit television procedure authorized by § 9-102 violated the defendant’s common law and due process right of presence in that “the witness testified in a separate room, in which he was not permitted.” 310 Md. at 529 , 530 A.2d 275 . | 1 | 1988–1988 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.