122 Md. App. 671 - Pryor v. State’s Empirical Analysis
1998
Citation profile
64 state decisions
How this case has been cited
Cited by 64 later decisions — most recently November 2018 · most notably Ferris v. State (1999), Cartnail v. State (2000)
64 state decisions
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 Terry v. Ohio · Carroll v. United States · Whren v. United States · United States v. Place · McMillian v. State
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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[U]nless continued detention can be justified by what occurs during the brief period of time it takes to determine whether the motorist has a valid license and whether the vehicle has been reported stolen, a motorist who is subjected to a ‘Whren stop” for a minor traffic violation cannot be detained at the scene of the stop longer than it takes — or reasonably should take — to issue a citation for the traffic violation that the motorist committed.”
5 later decisions quote this exact passage“The Fourth Amendment permits the forcible stop of a motorist who is observed by a law enforcement officer to be violating a “rule of the road.” The Fourth Amendment also permits the forcible stop of a vehicle when there is reasonable articulable suspicion to believe that its occupants are involved in criminal activity. In neither of these situations, however, may the occupants of the vehicle be detained for an extended period of time. In the absence of a justification for continued detention that manifests itself during the period of time reasonably necessary for the officer to (1) investigate the driver’s sobriety and license status, (2) establish that the vehicle has not been reported stolen, and (3) issue a traffic citation, the Fourth Amendment prohibits a detention in excess of that period of time. In this case, whether the period of appellant’s detention is characterized as a “first” (traffic) stop followed by a “second” (drug investigation) stop or as a single stop that was justifiable for two different reasons, appellant was detained much longer than was reasonable. The evidence derived from that unreasonable detention was acquired in violation of his Fourth Amendment rights.”
3 later decisions quote this exact passage“[t]his is not a case in which an extended detention of the motorist could be justified by the need to administer a `field sobriety' test or by technical difficulties in determining the status of the motorist's license or the ownership of the vehicle that has been stopped.”
2 later decisions quote this exact passagee.g. Wilkes v. State · Byndloss v. State
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.