2003 Pa. Super. 430 - Commonwealth v. Brown’s Empirical Analysis
2003
Citation profile
5
cited by 5 later decisions
1
states following
May 2013
most recently cited
5 state decisions
Relationships
Relies on Aguilar v. Texas · Spinelli v. United States · Commonwealth v. Carter · Commonwealth v. Hall · Commonwealth v. D'ANGELO
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Generally speaking, the production of an informant is a discovery matter and subject to the following test set forth in [Commonwealth v.] Bonasorte [, 337 Pa.Super. 332 , 486 A.2d 1361 (1984)]: we hold that a defendant seeking production of a confidential informant at a suppression hearing must show that production is material to his defense, reasonable, and in the interest of justice. By this we mean that the defendant must demonstrate some good faith basis in fact to believe that a police officer-affiant willfully has included misstatements of facts in an affidavit of probable cause which misrepresents either the existence of the informant or the information conveyed by the informant; that without the informant’s information there would not have been probable cause; and that production of the informant is the only way in which the defendant can substantiate this claim. Bonasorte, 486 A.2d at 1373-74 . However, the Bonasorte rule must be considered in conjunction with the holding in [Commonwealth v.] Miller [, 513 Pa. 118 , 518 A.2d 1187 (1986)] that “the [Commonwealth v.] Hall [, 451 Pa. 201 , 302 A.2d 342 (1973),] rule does not permit the disclosure of the identity of an informant relied upon by the affiant where it is established that the disclosure of such information would jeopardize the safety of the nongovernmental informant. This ruling also embraces the disclosure of information that would lead directly to the ascertainment of the identity of the informant.” Miller,”
2 later decisions quote this exact passage
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.