United States v. Sprinkle’s Empirical Analysis
106 F.3d 613 · 1997
Citation profile
41 federal appellate · 9 district · 37 state decisions
How this case has been cited
Cited by 135 later decisions — most recently January 2024 · most notably Ferris v. State (1999), United States v. Branch (2008)
41 federal appellate · 9 district · 37 state decisions — followed in 17 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 18 U.S.C. § 922 (Brady Handgun Violence Prevention Act)
Relies on Terry v. Ohio · Ornelas v. United States · United States v. Cortez · Brown v. Illinois · United States v. Sokolow
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 135 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If a suspect’s response to an illegal stop is itself a new distinct crime, then the police constitutionally may arrest the suspect for that crime. There is a strong policy reason for holding that a new and distinct crime, even if triggered by an illegal stop, is a sufficient intervening event to provide independent grounds for arrest.... [A] contrary rule would virtually immunize a defendant from prosecution for all crimes he might commit that have a sufficient causal connection to the police misconduct. Because the arrest for the new, distinct crime is lawful, evidence seized in a search incident to that lawful arrest is admissible.”
5 later decisions quote this exact passage · from the majority“an area's disposition toward criminal activity”
2 later decisions quote this exact passage · from the majority“Several factors distinguish Lender . First, although police could not see into Lender’s open hand, the fact that several men were looking into his hand indicated there was actually something in it. Here, although Poindexter and Sprinkle had their hands close together, [police] were able to see that their hands appeared empty. Thus ... initial suspicion that Sprinkle was about to pass something to Poindexter was simply not confirmed by what [police] actually saw. Second, Lender engaged in what we considered evasive conduct when he turned his back on approaching officers and walked away. Here the district court found that Poindexter was not being evasive. Third, in Lender we determined that the lateness of the hour (1:00 a.m.) properly contributed to reasonable suspicion. Poindexter was parked in broad daylight on a busy street with people all around. In sum, Lender is distinguishable to the point that it is not controlling. Id.”
1 later decision quote this exact passage · from the majoritye.g. State v. Taylor
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.