low bar in Maryland

2026“Having ‘any tendency’ to make ‘any fact’ more or less probable 31 is a very low bar to meet.” Montague, 471 Md. at 674 (quoting Williams, 457 Md. at 564 ) (further citation omitted).

2025Jarvis, 487 Md. at 563–64 (alterations in original). 9 IV ANALYSIS Given the low bar of the “some evidence” standard, discussed in detail below, we hold that Mr. Danshin met that bar through his statements made to police and introduced as evidence at trial.

2014Bass v. State, 206 Md.App. 1, 11 , 47 A.3d 582 (2012) (citation and quotation omitted).

2014Bass v. State, 206 Md.App. 1, 11 , 47 A.3d 582 (2012) (citation and quotation omitted).

2014As we have previously explained at some length, for trial counsel to pass the Strickland test, his performance need only exceed the low bar of “incompetence under prevailing professional norms,” whereas, for trial counsel to satisfy the “due diligence” demanded by Rule 4-331(c) and the actual innocence statute, CP § 8-301, his performance must meet the different (and not entirely overlapping) standard of acting “reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him.” Argyrou, 349 Md. at 605 , 709 A.2d 1194 . *25 The decisi

2014As we have previously explained at some length, for trial counsel to pass the Strickland test, his performance need only exceed the low bar of “incompetence under prevailing professional norms,” whereas, for trial counsel to satisfy the “due diligence” demanded by Rule 4-331(c) and the actual innocence statute, CP § 8-301, his performance must meet the different (and not entirely overlapping) standard of acting “reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him.” Argyrou, 349 Md. at 605 , 709 A.2d 1194 . *25 The decisi

2014As we have previously explained at some length, for trial counsel to pass the Strickland test, his performance need only exceed the low bar of “incompetence under prevailing professional norms,” whereas, for trial counsel to satisfy the “due diligence” demanded by Rule 4-331(c) and the actual innocence statute, CP § 8-301, his performance must meet the different (and not entirely overlapping) standard of acting “reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him.” Argyrou, 349 Md. at 605 , 709 A.2d 1194 . *25 The decisi

2014As we have previously explained at some length, for trial counsel to pass the Strickland test, his performance need only exceed the low bar of “incompetence under prevailing professional norms,” whereas, for trial counsel to satisfy the “due diligence” demanded by Rule 4-331(c) and the actual innocence statute, CP § 8-301, his performance must meet the different (and not entirely overlapping) standard of acting “reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him.” Argyrou, 349 Md. at 605 , 709 A.2d 1194 . *25 The decisi

2014As we have previously explained at some length, for trial counsel to pass the Strickland test, his performance need only exceed the low bar of “incompetence under prevailing professional norms,” whereas, for trial counsel to satisfy the “due diligence” demanded by Rule 4-331(c) and the actual innocence statute, CP § 8-301, his performance must meet the different (and not entirely overlapping) standard of acting “reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him.” Argyrou, 349 Md. at 605 , 709 A.2d 1194 . *25 The decisi

2014As we have previously explained at some length, for trial counsel to pass the Strickland test, his performance need only exceed the low bar of “incompetence under prevailing professional norms,” whereas, for trial counsel to satisfy the “due diligence” demanded by Rule 4-331(c) and the actual innocence statute, CP § 8-301, his performance must meet the different (and not entirely overlapping) standard of acting “reasonably and in good faith to obtain the evidence, in light of the totality of the circumstances and the facts known to him.” Argyrou, 349 Md. at 605 , 709 A.2d 1194 . *25 The decisi

2012Ultimately, the Potter Court held that California would allow recovery in tort for fear of cancer due to toxic exposure if the plaintiff already had contracted a physical injury or illness from the exposure or, if not, if the plaintiff proved (1) exposure to a toxic substance which threatens cancer, and (2) that the “fear stems from a knowledge, corroborated by reliable medical or scientific opinion, that it is more likely than not that the plaintiff will develop cancer in the future due to the toxic exposure.” Id., 25 Cal.Rptr.2d 550 , 863 P.2d at 816 . (emphasis added).

2012Ultimately, the Potter Court held that California would allow recovery in tort for fear of cancer due to toxic exposure if the plaintiff already had contracted a physical injury or illness from the exposure or, if not, if the plaintiff proved (1) exposure to a toxic substance which threatens cancer, and (2) that the “fear stems from a knowledge, corroborated by reliable medical or scientific opinion, that it is more likely than not that the plaintiff will develop cancer in the future due to the toxic exposure.” Id., 25 Cal.Rptr.2d 550 , 863 P.2d at 816 . (emphasis added).