2003 Pa. Super. 365 - Commonwealth v. Johnson’s Empirical Analysis

Citation profile

6 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Where, as here, the detention at issue follows a prior valid traffic stop, an arresting officer must demonstrate cause for suspicion after the end of the initial stop independent of any basis on which he conducted that stop. See Ortiz, 786 A.2d at 266 (“Without existence of a reasonable suspicion after the first encounter had ended, the second detention was unlawful”). Thus, in Ortiz , we recognized that even where a defendant’s conduct during the initial stop “may have merited further inquiry,” the arresting officer’s instruction to the defendant that he was free to leave vitiated any grounds he had to hold the defendant further. See id., 786 A.2d at 266 . Absent some new observation of suspicious circumstances, the defendant’s continued detention was illegal.”

   1 later decision quote this exact passage
   e.g. 2008 Pa. Super. 274 - Commonwealth v. Kemp

2. “Reasonable suspicion exists only where the officer is able to articulate specific observations which, in conjunction with reasonable inferences derived from those observations, led him reasonably to conclude, in light of his experience, that criminal activity was afoot and that the person he stopped was involved in that activity. Therefore, the fundamental inquiry of a reviewing court must be an objective one, namely, whether the facts available to the officer at the moment of intrusion warrant a man of reasonable caution in the belief that the action taken was appropriate.”

   1 later decision quote this exact passage
   e.g. 2005 Pa. Super. 166 - Commonwealth v. Jones