152 Md. App. 1 - Sellman v. State’s Empirical Analysis

Citation profile

14 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[A]n inventory search must at a bare minimum be a search of lawfully detained property carried out by a police officer in accordance with standard policies established by the officer’s law enforcement agency. Without the existence of a standard policy, an officer’s actions in conducting the search are not sufficiently regulated to assure that the search is in furtherance of legitimate police caretaking functions, unrelated to the existence vel non of probable cause, and not in furtherance of the officer’s own investigatory motives.”

   2 later decisions quote this exact passage
   e.g. 234 Md. App. 252 - State v. Paynter · 192 Md. App. 653 - Thompson v. State

2. “We agree with the State that the facts in evidence do not point in the direction of a pretextual search. Nevertheless, as we have explained, the Supreme Court case law requires that, for a search to in fact be a valid inventory search in the eyes of Fourth Amendment law, there must be proof that the search was carried out pursuant to an existing policy regulating police inventory searches. That evidence is essential to establishing the inventory search exception, regardless of whether the total circumstances seem more consistent with the search’s having been performed for a community caretaking purpose than for an investigatory purpose.”

   1 later decision quote this exact passage
   e.g. 234 Md. App. 252 - State v. Paynter

3. “While in argument the prosecutor made reference to Anne Arundel County’s having a policy that all vehicles subject to being towed are to be searched, and while such a policy may exist (and may even have been known by the trial judge to exist), we must base our decision on the evidence actually presented at trial. There was no evidence of any standardized policy, rule, or regulation of any sort governing inventory searches by Anne Arundel County police officers; and there was no evidence that Officer Novotny carried out his search in accordance with any such policy.”

   1 later decision quote this exact passage
   e.g. 234 Md. App. 252 - State v. Paynter