15 Va. App. 127 - Commonwealth v. Satchell’s Empirical Analysis

Citation profile

15 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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In mid-afternoon on December 18, 1991, Sergeant John Buckovich, who was dressed in plain clothes and traveling in an unmarked police car, saw [Satchell] standing with two other individuals on a Richmond street comer known to Buckovich as an area for narcotics trafficking. Buckovich saw [Satchell] hand money to one man and receive something in return. The three men saw the police car as it approached and immediately started to walk away in separate directions. [Satchell] walked to a door stoop, but was unable to enter the locked door. From these observations, Buckovich believed that criminal activity was transpiring. Buckovich, who had a badge around his neck, approached [Satchell] on the stoop and identified himself. He asked [Satchell], “What’s in your hand, pal?” [Satchell] showed his left hand, which was empty. Buckovich then asked [Satchell] what was in his other hand. [Satchell] opened his right hand, which contained two packages of cocaine. Buckovich arrested [Satchell]. Buckovich testified that until he observed the cocaine and made the arrest, Satchell was free to leave at any time or to ignore Buckovich’s questions.”

   1 later decision quote this exact passage
   e.g. 20 Va. App. 641 - Satchell v. Commonwealth

2. “Although the Mendenhall test “is necessarily imprecise” and “flexible enough to be applied to the whole range of police conduct in an equally broad range of settings, it calls for consistent application from one police encounter to the next, regardless of the particular individual’s response to the action of the police.” Whether a person who encounters a police officer believes he is free to leave must be measured under all the circumstances by an “objective standard— looking to the reasonable man’s interpretation of the conduct in question.” Whether a seizure has taken place involves factual determinations which bear upon whether a reasonably prudent person would feel that he or she is not free to leave, but whether the evidence is sufficient to support a finding that a seizure has occurred is ultimately a question of law.”

   1 later decision quote this exact passage
   e.g. 20 Va. App. 641 - Satchell v. Commonwealth

3. “[A] law enforcement officer does not violate the fourth amendment by merely approaching an individual in a public place and asking questions of the person if the individual is willing or chooses to remain and answer them. There must be some coercion or show of force or authority by the officer, measured by objective standards, that would cause a person so situated reasonably to have believed that he or she was required to comply with the officer’s requests.”

   1 later decision quote this exact passage
   e.g. 20 Va. App. 641 - Satchell v. Commonwealth