13 Maryland opinions name it 2 courts 1987–2025 2 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 |
|---|---|---|
McCall v. Stategreen2 sentences2025The factual basis requirement ensures that the defendant does not plead guilty “without realizing that his conduct does not actually fall within the charge.” McCall v. State, 9 Md. 2009As we explained in Metheny , the primary purpose of the factual basis requirement of Maryland Rule 4-242(c) is to ensure that the accused is not convicted of a crime that he or she did not commit. 359 Md. at 602-03 , 755 A.2d at 1103 ; cf. State v. Thornton, 73 Md.App. 247, 255 , 533 A.2d 951, 955 (1987) (explaining that the factual basis requirement “protect[s] a defendant who is in the position of pleading voluntarily with an understanding of the nature of the charge but without realizing that his conduct does not actually fall within the charge”)(citing McCall v. State, 9 Md.App. 191, 199 , | 2 | 3 |
State v. Thorntongreen2 sentences2009As we explained in Metheny , the primary purpose of the factual basis requirement of Maryland Rule 4-242(c) is to ensure that the accused is not convicted of a crime that he or she did not commit. 359 Md. at 602-03 , 755 A.2d at 1103 ; cf. State v. Thornton, 73 Md.App. 247, 255 , 533 A.2d 951, 955 (1987) (explaining that the factual basis requirement “protect[s] a defendant who is in the position of pleading voluntarily with an understanding of the nature of the charge but without realizing that his conduct does not actually fall within the charge”)(citing McCall v. State, 9 Md.App. 191, 199 , 2009As we explained in Metheny , the primary purpose of the factual basis requirement of Maryland Rule 4-242(c) is to ensure that the accused is not convicted of a crime that he or she did not commit. 359 Md. at 602-03 , 755 A.2d at 1103 ; cf. State v. Thornton, 73 Md.App. 247, 255 , 533 A.2d 951, 955 (1987) (explaining that the factual basis requirement “protect[s] a defendant who is in the position of pleading voluntarily with an understanding of the nature of the charge but without realizing that his conduct does not actually fall within the charge”)(citing McCall v. State, 9 Md.App. 191, 199 , | 1 | 4 |
Harris v. Cartergreen2 sentences2004We held: Reversal is required because appellee’s motion to vacate the order of default contained neither a legal nor a factual basis for a defense of the claim. 71 Md.App. at 263 , 524 A.2d 1250 . 2004We held: Reversal is required because appellee’s motion to vacate the order of default contained neither a legal nor a factual basis for a defense of the claim. 71 Md.App. at 263 , 524 A.2d 1250 . | 1 | 2 |
McCarthy v. United Statesgreen2 sentences1987When the factual-basis requirement is not satisfied, ... the question of voluntariness is left open____ [Mjerely ordering a voluntariness hearing is likely to be an ineffectual means of assuring that the defendant’s rights were protected when the plea was taken, inasmuch as the defendant’s subjective state of mind is crucial and his proof is likely to be “limited to his own plaintive allegations.” Id. {citing McCarthy, 394 U.S. at 469 , 89 S.Ct. at 1172 ). 1987When the factual-basis requirement is not satisfied, ... the question of voluntariness is left open____ [Mjerely ordering a voluntariness hearing is likely to be an ineffectual means of assuring that the defendant’s rights were protected when the plea was taken, inasmuch as the defendant’s subjective state of mind is crucial and his proof is likely to be “limited to his own plaintive allegations.” Id. {citing McCarthy, 394 U.S. at 469 , 89 S.Ct. at 1172 ). | 1 | 2 |
Arthur v. Stategreen1 sentence2025“The ‘some evidence’ standard is a ‘fairly low hurdle[,]’” Hollins v. State, 489 Md. 296 , 311 (2024) (quoting Arthur v. State, 420 Md. 512, 526 (2011)), as it is satisfied by the existence of any evidence, from any source, and from either party, that, if believed, would supply a factual basis for the instruction. | 1 | 1 |
Covington v. Stategreen1 sentence2020That does not mean that the State must prove its case before the court may accept a guilty plea, or that a guilty plea hearing is akin to a trial on a stipulated set of facts.4 Rather, the factual basis inquiry confirms that the plea is “truly 4 “The plea of not guilty, accompanied by an ‘Agreed Statement of Facts,’ is a peculiar animal.” Covington v. State, 282 Md. 540, 541 (1978) (quoting Covington v. State, 34 Md. | 1 | 1 |
Covington v. Stategreen1 sentence2020That does not mean that the State must prove its case before the court may accept a guilty plea, or that a guilty plea hearing is akin to a trial on a stipulated set of facts.4 Rather, the factual basis inquiry confirms that the plea is “truly 4 “The plea of not guilty, accompanied by an ‘Agreed Statement of Facts,’ is a peculiar animal.” Covington v. State, 282 Md. 540, 541 (1978) (quoting Covington v. State, 34 Md. | 1 | 1 |
Paulsen v. Mansongreen2 sentences2000Cf. Paulsen v. Manson, 203 Conn. 484 , 525 A.2d 1315, 1318 (1987)(overruling prior cases that held the factual basis requirement was constitutionally mandated in light of federal courts of appeal precedent). 2000Cf. Paulsen v. Manson, 203 Conn. 484 , 525 A.2d 1315, 1318 (1987)(overruling prior cases that held the factual basis requirement was constitutionally mandated in light of federal courts of appeal precedent). | 1 | 1 |
State v. Shafergreen1 sentence2000See also Boykin v. Alabama, 395 U.S. 238, 243 , 89 S.Ct. 1709, 1712 , 23 L.Ed.2d 274, 279 (1969); State v. Shafer, 969 S.W.2d 719, 731-32 (Mo. 1998). [15] The factual basis requirement has also been referred to, in one of the few treatises on the topic, as the "accuracy requirement." See John L. | 1 | 1 |
Boykin v. Alabamagreen2 sentences2000See also Boykin v. Alabama, 395 U.S. 238, 243 , 89 S.Ct. 1709, 1712 , 23 L.Ed.2d 274, 279 (1969); State v. Shafer, 969 S.W.2d 719, 731-32 (Mo. 1998). [15] The factual basis requirement has also been referred to, in one of the few treatises on the topic, as the "accuracy requirement." See John L. 2000See also Boykin v. Alabama, 395 U.S. 238, 243 , 89 S.Ct. 1709, 1712 , 23 L.Ed.2d 274, 279 (1969); State v. Shafer, 969 S.W.2d 719, 731-32 (Mo. 1998). [15] The factual basis requirement has also been referred to, in one of the few treatises on the topic, as the "accuracy requirement." See John L. | 1 | 1 |
Davis v. Stategreen2 sentences2000See McCarthy v. United States, 394 U.S. 459, 466 , 89 S.Ct. 1166, 1171 , 22 L.Ed.2d 418, 425 (1969); Davis v. State, 278 Md. 103, 110 , 361 A.2d 113, 117 (1976). 2000See McCarthy v. United States, 394 U.S. 459, 466 , 89 S.Ct. 1166, 1171 , 22 L.Ed.2d 418, 425 (1969); Davis v. State, 278 Md. 103, 110 , 361 A.2d 113, 117 (1976). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Pablo Carreon v. United States
green
2 sentences1991In Carreon v. United States, 578 F.2d 176 (7th Cir.1978), the appellate court found the trial court had violated the factual basis requirement of Rule 11 by relying on counsel’s statement that the defendant had been informed about possible defenses. 1987In Carreon v. U.S., 578 F.2d 176 (7th Cir.1978), the appellate court found the trial court had violated the factual basis requirement of Rule 11 by relying on counsel’s statement that the defendant had been informed about possible defenses. | 2 | 1987–1991 |
Ross v. Housing Authority
green
1 sentence2017Factual Basis Requirement for Expert Opinion Testimony in Lead Paint Litigation Maryland Rule 5-702 states that “[e]xpert testimony may be admitted, in the form of an opinion or otherwise, if the court determines that the testimony will assist the trier of fact to understand the evidence or to determine a fact in issue.” A trial court “bases this determination on three factors,” one of which is “‘whether a sufficient factual basis exists to support the expert testimony.’” Id. | 1 | 2017–2017 |
Buskirk v. C.J. Langenfelder & Son, Inc.
green
2 sentences2012Appellant replies that the holding in Buskirk, 136 Md.App. at 263-64 , 764 A.2d 857 , regarding a “basis in fact,” requires only that the claimant have a factual basis for the claim, not that the factual basis be specifically set forth at the time of filing the Petition to Reopen. 2012Appellant replies that the holding in Buskirk, 136 Md.App. at 263-64 , 764 A.2d 857 , regarding a “basis in fact,” requires only that the claimant have a factual basis for the claim, not that the factual basis be specifically set forth at the time of filing the Petition to Reopen. | 1 | 2012–2012 |
Metheny v. State
green
2 sentences2009As we explained in Metheny , the primary purpose of the factual basis requirement of Maryland Rule 4-242(c) is to ensure that the accused is not convicted of a crime that he or she did not commit. 359 Md. at 602-03 , 755 A.2d at 1103 ; cf. State v. Thornton, 73 Md.App. 247, 255 , 533 A.2d 951, 955 (1987) (explaining that the factual basis requirement “protect[s] a defendant who is in the position of pleading voluntarily with an understanding of the nature of the charge but without realizing that his conduct does not actually fall within the charge”)(citing McCall v. State, 9 Md.App. 191, 199 , 2009As we explained in Metheny , the primary purpose of the factual basis requirement of Maryland Rule 4-242(c) is to ensure that the accused is not convicted of a crime that he or she did not commit. 359 Md. at 602-03 , 755 A.2d at 1103 ; cf. State v. Thornton, 73 Md.App. 247, 255 , 533 A.2d 951, 955 (1987) (explaining that the factual basis requirement “protect[s] a defendant who is in the position of pleading voluntarily with an understanding of the nature of the charge but without realizing that his conduct does not actually fall within the charge”)(citing McCall v. State, 9 Md.App. 191, 199 , | 1 | 2009–2009 |
State v. Zhao
green
1 sentence2008Doing so supports a flexible plea bargaining system through which a defendant can choose to plead guilty to a related charge that was not committed, in order to avoid near certain conviction for a greater offense.” Id. at 841 . | 1 | 2008–2008 |
Parren v. State
green
2 sentences2007Appellant also argues, relying principally on this Court’s decision in Parren v. State, 89 Md.App. 645 , 599 A.2d 828 (1991), that the circuit court “erred in denying coram nobis relief to [ajppellant on the basis that his Alford plea[ ] w[as] entered without a factual basis being set forth on the record,” and thus appellant’s guilty plea was “neither knowing nor voluntary.” Specifically, appellant contends that, during his guilty plea, “[a]ll the trial court did in this case was establish that [ajppellant had read, at some point in time, the Statement of Charges and that he understood it.” Ac 2007Appellant also argues, relying principally on this Court’s decision in Parren v. State, 89 Md.App. 645 , 599 A.2d 828 (1991), that the circuit court “erred in denying coram nobis relief to [ajppellant on the basis that his Alford plea[ ] w[as] entered without a factual basis being set forth on the record,” and thus appellant’s guilty plea was “neither knowing nor voluntary.” Specifically, appellant contends that, during his guilty plea, “[a]ll the trial court did in this case was establish that [ajppellant had read, at some point in time, the Statement of Charges and that he understood it.” Ac | 1 | 2007–2007 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.