People v. Ramirez’s Empirical Analysis
1980
Citation profile
2 federal appellate · 50 state decisions
How this case has been cited
Cited by 54 later decisions (2 by the Supreme Court) — most recently April 2015 · most notably Berkemer v. McCarty (1984), Commonwealth v. Brennan (1982)
2 federal appellate · 50 state decisions — followed in 12 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 Miranda v. State of Arizona Vignera · Schneckloth v. Bustamonte · United States v. Wade · Schmerber v. State of California · Gilbert v. California
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 54 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“are premised upon the relationships between intoxication and the externally manifested loss of coordination which it causes. These tests do not seek to compel from the defendant any knowledge he might have: nor do they involve the defendant’s communicative facilities in any way. They only compel him to exhibit his physical characteristics of coordination. [Emphasis added; citations omitted.]”
2 later decisions quote this exact passage · from the majority“Field sobriety tests are based on the relationship between intoxication and the loss of coordination which intoxication causes. These tests do not force the subject to betray his subjective knowledge through his communicative facilities. They only compel the suspect to exhibit his physical characteristics of coordination as a source of real or physical evidence which may be testified to by the officer observing the tests. They require the suspect "to stand, to assume a stance, to walk, or to make a gesture" within the purview of Schmerber . We note, as the Schmerber court did, that "[s]ome tests seemingly directed to obtain `physical evidence,' for example, lie detector tests measuring changes in body function during interrogation, may actually be directed to eliciting responses which are essentially testimonial." In this instance, however, no such problem exists. Thus, we believe that field sobriety tests are physical and real evidence and do not activate the protections afforded by the Fifth Amendment.”
1 later decision quote this exact passage · from the majority“tests are based on the loss of coordination, balance and dexterity that results from intoxication, [and] they do not force the subject to betray his subjective knowledge of the crime through communication or testimony.”
1 later decision quote this exact passage · from the majoritye.g. Farmer v. Com.
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.