16 Maryland opinions name it 2 courts 1983–2021 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 |
|---|---|---|
Conyers v. Stategreen2 sentences2018See id. (holding "that the trial judge did not abuse his discretion by refusing to admit the separate hearsay statement under the doctrine of verbal completeness."). 2018We again limited the common law doctrine of verbal completeness in Conyers v. State , 345 Md. 525 , 693 A.2d 781 (1997). | 5 | 10 |
Rutherford v. Stategreen2 sentences2018"The common law doctrine of verbal completeness 'allows a party to respond to the admission, by an opponent, of part of a writing or conversation, by admitting the remainder of that writing or conversation.' " Rutherford v. State , 160 Md. 2018“The common law doctrine of verbal completeness ‘allows a party to respond to the admission, by an opponent, of part of a writing or conversation, by admitting the remainder of that writing or conversation.’” Rutherford v. State, 160 Md. | 2 | 3 |
Richardson v. Stategreen2 sentences2018Some years later, this Court clarified and further limited the doctrine of verbal completeness in Richardson v. State , 324 Md. 611 , 598 A.2d 180 (1991). 2018Some years later, this Court clarified and further limited the doctrine of verbal completeness in Richardson v. State , 324 Md. 611 , 598 A.2d 180 (1991). | 1 | 3 |
Bowers v. Stategreen2 sentences1991The purpose of offering McCoy’s hearsay was not to establish what McCoy heard from Richardson, but was to establish when McCoy heard from Richardson. *622 The State argued, and the trial judge held, that Detective Dominic’s report was admissible in redirect examination of Detective Marll under the “doctrine of verbal completeness.” In Bowers v. State, 298 Md. 115 , 468 A.2d 101 (1983), this Court discussed the effect of introducing part of a writing or conversation. 1991The purpose of offering McCoy’s hearsay was not to establish what McCoy heard from Richardson, but was to establish when McCoy heard from Richardson. *622 The State argued, and the trial judge held, that Detective Dominic’s report was admissible in redirect examination of Detective Marll under the “doctrine of verbal completeness.” In Bowers v. State, 298 Md. 115 , 468 A.2d 101 (1983), this Court discussed the effect of introducing part of a writing or conversation. | 1 | 3 |
Grove v. Stategreen1 sentence2021“Of course, parts of the conversation having no reference whatever to the issue upon trial are not admissible under the rule[.]” Grove v. State, 185 Md. 476, 479 (1946) (quoting People v. Bowen, 135 N.W. 824, 827 (Mich. 1912)). 44 The ostensibly incomplete statements in the redacted video and transcript on which Mr. Westley relies consist of generic references by Ms. Fleming: (1) indicating prior familiarity with Victim, including stating that Victim looked “taller since the last time,” asking, “How old are you now?,” and remarking that Victim was “living in Salisbury” the last time they had t | 1 | 1 |
Otto v. Stategreen1 sentence2021“Determining whether separate statements are admissible under the doctrine of verbal completeness is . . . to be reviewed for an abuse of discretion.” Otto v. State, 459 Md. 423, 446 (2018). | 1 | 1 |
Des Champlain v. Des Champlaingreen1 sentence2021“Of course, parts of the conversation having no reference whatever to the issue upon trial are not admissible under the rule[.]” Grove v. State, 185 Md. 476, 479 (1946) (quoting People v. Bowen, 135 N.W. 824, 827 (Mich. 1912)). 44 The ostensibly incomplete statements in the redacted video and transcript on which Mr. Westley relies consist of generic references by Ms. Fleming: (1) indicating prior familiarity with Victim, including stating that Victim looked “taller since the last time,” asking, “How old are you now?,” and remarking that Victim was “living in Salisbury” the last time they had t | 1 | 1 |
Smith v. Stategreen2 sentences1986See, e.g., Smith v. State, 273 Md. 152, 161 , 328 A.2d 274 (1974). 1986See, e.g., Smith v. State, 273 Md. 152, 161 , 328 A.2d 274 (1974). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Feigley v. Baltimore Transit Co.
green
2 sentences1983Transit Co., 211 Md. 1, 10 , 124 A.2d 822 (1956), he relies also on the verbal completeness doctrine. 1983Transit Co., 211 Md. 1, 10 , 124 A.2d 822 (1956), he relies also on the verbal completeness doctrine. | 2 | 1983–2018 |
Churchfield v. State
green
2 sentences2018Petitioner also requests that this Court follow the analysis utilized in Churchfield v. State , 137 Md. 2018Id. at 691-92 , 769 A.2d at 326 -27 . | 2 | 2004–2018 |
Smith v. Wood
green
1 sentence2018The application of the common law doctrine of verbal completeness requires that "[t]he offer in testimony of a part of a statement or conversation, upon a well-established rule of evidence, always gives to the opposite party the right to have the whole." Smith v. Wood , 31 Md. 293 , 296-97 (1869). | 1 | 2018–2018 |
Alexis v. State
green
2 sentences2018An abuse of discretion exists where "no reasonable person would take the view adopted by the [trial] court, or when the court acts without reference to any guiding rules or principles." Alexis v. State , 437 Md. 457 , 478, 87 A.3d 1243 , 1254 (2014). 2018An abuse of discretion exists where "no reasonable person would take the view adopted by the [trial] court, or when the court acts without reference to any guiding rules or principles." Alexis v. State , 437 Md. 457 , 478, 87 A.3d 1243 , 1254 (2014). | 1 | 2018–2018 |
Valdes v. United States
green
2 sentences2004As we shall explain, the court did not abuse its discretion in refusing appellant’s request. *320 The common law doctrine of verbal completeness “allows a party to respond to the admission, by an opponent, of part of a writing or conversation, by admitting the remainder of that writing or conversation.” Conyers v. State, 345 Md. 525, 541 , 693 A.2d 781 (1997), cert. denied, 528 U.S. 910 , 120 S.Ct. 258 , 145 L.Ed.2d 216 (1999). 2004As we shall explain, the court did not abuse its discretion in refusing appellant’s request. *320 The common law doctrine of verbal completeness “allows a party to respond to the admission, by an opponent, of part of a writing or conversation, by admitting the remainder of that writing or conversation.” Conyers v. State, 345 Md. 525, 541 , 693 A.2d 781 (1997), cert. denied, 528 U.S. 910 , 120 S.Ct. 258 , 145 L.Ed.2d 216 (1999). | 1 | 2004–2004 |
State v. Lynn
green
2 sentences2004As we shall explain, the court did not abuse its discretion in refusing appellant’s request. *320 The common law doctrine of verbal completeness “allows a party to respond to the admission, by an opponent, of part of a writing or conversation, by admitting the remainder of that writing or conversation.” Conyers v. State, 345 Md. 525, 541 , 693 A.2d 781 (1997), cert. denied, 528 U.S. 910 , 120 S.Ct. 258 , 145 L.Ed.2d 216 (1999). 2004As we shall explain, the court did not abuse its discretion in refusing appellant’s request. *320 The common law doctrine of verbal completeness “allows a party to respond to the admission, by an opponent, of part of a writing or conversation, by admitting the remainder of that writing or conversation.” Conyers v. State, 345 Md. 525, 541 , 693 A.2d 781 (1997), cert. denied, 528 U.S. 910 , 120 S.Ct. 258 , 145 L.Ed.2d 216 (1999). | 1 | 2004–2004 |
Graves v. State
green
2 sentences1997Hearsay' has been defined as “a statement, other than one made by the declarant while testifying at the trial ..., offered in evidence to prove the truth of the matter asserted.” Graves v. State, 334 Md. 30 , 36 n. 2, 637 A.2d 1197 , 1201 n. 2 (1994). 1997Hearsay' has been defined as “a statement, other than one made by the declarant while testifying at the trial ..., offered in evidence to prove the truth of the matter asserted.” Graves v. State, 334 Md. 30 , 36 n. 2, 637 A.2d 1197 , 1201 n. 2 (1994). | 1 | 1997–1997 |
Newman v. State
green
2 sentences1987In Newman v. State, 65 Md.App. 85 , 499 A.2d 492 , cert. denied, 305 Md. 419 , 504 A.2d 1152 (1986), we discussed at length the doctrine of verbal completeness. 1987In Newman v. State, 65 Md.App. 85 , 499 A.2d 492 , cert. denied, 305 Md. 419 , 504 A.2d 1152 (1986), we discussed at length the doctrine of verbal completeness. | 1 | 1987–1987 |
Robinson v. State
green
2 sentences1986One of those theories is urged under the so-called doctrine of “curative admissibility.” Robinson v. State, 53 Md.App. 297 , 452 A.2d 1291 (1982). 2 The other theory is *254 urged under the “doctrine of verbal completeness.” 3 With respect to both theories, now offered for the first time, we see no difference between this and the situation before us in Braxton v. State, at 57 Md.App. 549 , 470 A.2d 1327 , where we declined to rule upon issues and theories of admissibility that had not been presented to the trial court: “[W]e note that at no time did defense counsel advise the court that he was 1986One of those theories is urged under the so-called doctrine of “curative admissibility.” Robinson v. State, 53 Md.App. 297 , 452 A.2d 1291 (1982). 2 The other theory is *254 urged under the “doctrine of verbal completeness.” 3 With respect to both theories, now offered for the first time, we see no difference between this and the situation before us in Braxton v. State, at 57 Md.App. 549 , 470 A.2d 1327 , where we declined to rule upon issues and theories of admissibility that had not been presented to the trial court: “[W]e note that at no time did defense counsel advise the court that he was | 1 | 1986–1986 |
Braxton v. State
green
1 sentence1986One of those theories is urged under the so-called doctrine of “curative admissibility.” Robinson v. State, 53 Md.App. 297 , 452 A.2d 1291 (1982). 2 The other theory is *254 urged under the “doctrine of verbal completeness.” 3 With respect to both theories, now offered for the first time, we see no difference between this and the situation before us in Braxton v. State, at 57 Md.App. 549 , 470 A.2d 1327 , where we declined to rule upon issues and theories of admissibility that had not been presented to the trial court: “[W]e note that at no time did defense counsel advise the court that he was | 1 | 1986–1986 |
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.