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8 Maryland opinions name it 2 courts 1978–2024 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 |
|---|---|---|
Westcoat v. Stategreen2 sentences1979Westcoat v. State, 231 Md. 364, 368 , 190 A. 2d 544, 546 (1963); Wilson v. State, 181 Md. 1, 3 , 26 A. 2d 770, 772 (1942); see Young v. State, 152 Md. 89, 91-92 , 136 A. 46, 47 (1927). 1979Westcoat v. State, 231 Md. 364, 368 , 190 A. 2d 544, 546 (1963); Wilson v. State, 181 Md. 1, 3 , 26 A. 2d 770, 772 (1942); see Young v. State, 152 Md. 89, 91-92 , 136 A. 46, 47 (1927). | 3 | 3 |
Wilson v. Stategreen2 sentences1979Westcoat v. State, 231 Md. 364, 368 , 190 A. 2d 544, 546 (1963); Wilson v. State, 181 Md. 1, 3 , 26 A. 2d 770, 772 (1942); see Young v. State, 152 Md. 89, 91-92 , 136 A. 46, 47 (1927). 1979Westcoat v. State, 231 Md. 364, 368 , 190 A. 2d 544, 546 (1963); Wilson v. State, 181 Md. 1, 3 , 26 A. 2d 770, 772 (1942); see Young v. State, 152 Md. 89, 91-92 , 136 A. 46, 47 (1927). | 3 | 3 |
Young v. Stategreen2 sentences1979Westcoat v. State, 231 Md. 364, 368 , 190 A. 2d 544, 546 (1963); Wilson v. State, 181 Md. 1, 3 , 26 A. 2d 770, 772 (1942); see Young v. State, 152 Md. 89, 91-92 , 136 A. 46, 47 (1927). 1979Westcoat v. State, 231 Md. 364, 368 , 190 A. 2d 544, 546 (1963); Wilson v. State, 181 Md. 1, 3 , 26 A. 2d 770, 772 (1942); see Young v. State, 152 Md. 89, 91-92 , 136 A. 46, 47 (1927). | 3 | 3 |
Cross v. Stategreen2 sentences2024To fit under the common scheme or plan exception, the Court wrote, there “‘must be more than simply a manner of operation, which is possessed to some extent by most criminal recidivists.’” Id. at 280 (quoting Cross v. State, 282 Md. 468, 475 (1978)). “‘A method of operation is not, by itself, a common scheme, but merely a repetitive pattern.’” Id. (quoting Cross v. State, 282 Md. at 475 ). 2024To fit under the common scheme or plan exception, the Court wrote, there “‘must be more than simply a manner of operation, which is possessed to some extent by most criminal recidivists.’” Id. at 280 (quoting Cross v. State, 282 Md. 468, 475 (1978)). “‘A method of operation is not, by itself, a common scheme, but merely a repetitive pattern.’” Id. (quoting Cross v. State, 282 Md. at 475 ). | 1 | 4 |
McKnight v. Stategreen2 sentences2024To fit under the common scheme or plan exception, the Court wrote, there “‘must be more than simply a manner of operation, which is possessed to some extent by most criminal recidivists.’” Id. at 280 (quoting Cross v. State, 282 Md. 468, 475 (1978)). “‘A method of operation is not, by itself, a common scheme, but merely a repetitive pattern.’” Id. (quoting Cross v. State, 282 Md. at 475 ). 1978The language used by the Court of Special Appeals, as we read that court’s opinion, to describe the common scheme or plan exception in fact describes the “handiwork” or “signature” exception discussed in McKnight v. State, 280 Md. 604, 613 , 375 A. 2d 551, 556 (1977), and at times referred to as the “modus operandi” form of the identity exception. | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
McKinney v. State
green
2 sentences2000In McKinney v. State, 82 Md.App. 111 , 570 A.2d 360 (1990), we recognized two ways in which other crimes evidence may come within the common scheme or plan exception: (1) a modus operands which is but one means of establishing identity ... or (2) a plan to commit one offense as part of a grand scheme to commit others, such as a theft of nitroglycerine for use in blowing open a safe. 2000In McKinney v. State, 82 Md.App. 111 , 570 A.2d 360 (1990), we recognized two ways in which other crimes evidence may come within the common scheme or plan exception: (1) a modus operands which is but one means of establishing identity ... or (2) a plan to commit one offense as part of a grand scheme to commit others, such as a theft of nitroglycerine for use in blowing open a safe. | 2 | 2000–2003 |
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.