108 Wash. 2d 193 - State v. Bell’s Empirical Analysis
1987
Citation profile
49 state decisions
How this case has been cited
Cited by 51 later decisions (2 by the Supreme Court) — most recently December 2021 · most notably Horton v. California (1990), 123 Wash. 2d 260 - City of Seattle v. McCready (1994)
49 state decisions — followed in 15 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
Relies on Coolidge v. New Hampshire · United States v. Place · Texas v. Brown · Sedillo v. United States · Michigan v. Tyler
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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[n]o person shall be disturbed in his private affairs ...”
3 later decisions quote this exact passage“Once the privacy of the residence has been lawfully invaded, it is senseless to require a warrant for others to enter and complete what those already on the scene would be justified in doing. We hold that where firefighters have lawfully discovered evidence of criminal activity under the plain view doctrine, it is not necessary for sheriffs officers to obtain a warrant before entering a residence to seize the evidence. There are, of course, limits on the actions of the police. When the police enter the residence, they are not allowed to exceed the scope of the firefighters’ earlier intrusion. In essence, they step into the shoes of the firefighters. They cannot enter any area that the firefighters were not justified in entering, nor seize any evidence that the firefighters were not justified in seizing.”
1 later decision quote this exact passagee.g. Wengert v. State“Once the privacy of the residence has been lawfully invaded, it is senseless to require a warrant for others to enter and complete what those already on the scene would be justified in doing. We hold that where firefighters have lawfully discovered evidence of criminal activity under the plain view doctrine, it is not necessary for sheriffs officers to obtain a warrant before entering a residence to seize the evidence.”
1 later decision quote this exact passagee.g. Mazen v. Seidel
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.