Munafo v. State’s Empirical Analysis

Citation profile

67 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[T]he purpose of a traffic stop is to issue a citation or warning. Once that purpose has been satisfied, the continued detention of a vehicle and its occupant(s) constitutes a second stop, and must be independently justified by reasonable suspicion.”

   6 later decisions quote this exact passage
   e.g. 239 Md. App. 440 - Steck v. State · 132 Md. App. 598 - Charity v. State

2. “Deputy Houck did not actually issue a citation or warning after receiving word that Munafo’s license and rental agreement were valid. Rather, he waited for Sergeant Elliott to arrive on the scene before approaching appellant a second time.”). 31 . See Robertson, 596 A.2d at 1351 . 32 . Most courts require something more than nervousness and implausible or conflicting answers to support a finding of reasonable suspicion — for example, insufficient documentation or the odor of masking agents. See, e.g., People v. Banks, 85 N.Y.2d 558 , 626 N.Y.S.2d 986 , 650 N.E.2d 833, 835 (1995) (”

   2 later decisions quote this exact passage
   e.g. 132 Md. App. 598 - Charity v. State · Caldwell v. State

3. “In [In re] Montrail M. [ 87 Md.App. 420 , 589 A.2d 1318 (1991)1 by contrast, we held that a single detention took place. In that case, a sheriffs deputy observed a station wagon parked outside a business in an isolated area early in the morning. There were three persons in the car. The deputy called for backup, knowing that the only other unit on duty at the time was a canine unit. The deputy spoke with the driver, and his suspicions were further aroused by the driver’s explanation of what he was doing in that particular location at 3:30 a.m. The deputy obtained the driver’s license and registration and began to run a check. Before the check was completed, the canine unit arrived, and the deputy conducted a quick scan of the station wagon. After the dog indicated that drugs were present, the deputy searched the car and found both marijuana and crack cocaine. Our analysis of the situation emphasized two points. First, the canine scan occurred during an otherwise valid stop, which was based on reasonable suspicion. At the time that the scan took place, the deputy was still awaiting the results of the license and registration check Second, we noted that the scan did not prolong the detention. Because the scan was conducted in a public place and did not inconvenience the car’s occupants, the scan itself did not constitute a search within the meaning of the Fourth Amendment.”

   1 later decision quote this exact passage
   e.g. 119 Md. App. 444 - Graham v. State