2004 Pa. Super. 17 - Commonwealth v. Johonoson’s Empirical Analysis
2004
Citation profile
13 state decisions
How this case has been cited
Cited by 13 later decisions — most recently May 2023
13 state decisions
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 Terry v. Ohio · Commonwealth v. Grant · Commonwealth v. Ellis · Commonwealth v. Allen · Office of Disciplinary Counsel v. Anonymous Attorney
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“By pulling over to the side of the road at 3:00 in the morning on a rural road, after driving slowly with his hazard lights on, Appellant should have had reason to expect that a police officer would pull over and attempt to render aid ... Appellant is exactly the sort of person whom [an officer] has a duty to assist. The fact that [the officer] activated his lights in the course of doing so does not turn the interaction into an investigative detention. Rather, it remained a mere encounter for which no suspicion of illegal activity was required.”
3 later decisions quote this exact passage“A primary purpose of both the Fourth Amendment and Article I, Section 8 “is to protect citizens from unreasonable searches and seizures.” In the Interest of D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (Pa.2001). Not every encounter between citizens and the police is so intrusive as to amount to a “seizure” triggering constitutional concerns. See Commonwealth v. Boswell, 554 Pa. 275 , 721 A.2d 336, 340 (Pa.1998) (opinion in support of affirmance) (citing Terry v. Ohio, 392 U.S. 1 , 20 n. 16, 88 S.Ct. 1868 , 20 L.Ed.2d 889 (1968)). This Court has noted that there are three basic categories of interactions between citizens and the police. The first category, a mere encounter or request for information, does not need to be supported by any level of suspicion, and does not carry any official compulsion to stop or respond. The second category, an investigative detention, derives from Terry v. Ohio and its progeny: such a detention is lawful if supported by reasonable suspicion because, although it subjects a suspect to a stop and a period of detention, it does not involve such coercive conditions as to constitute the functional equivalent of an arrest. The final category, the arrest or custodial detention, must be supported by probable cause. See [Commonwealth v.] Ellis, [ 541 Pa. 285 ,] 662 A.2d [1043] at 1047-48 [(1995)]; see also In the Interest of D.M., 781 A.2d at 1164 . This Court has acknowledged this approach to police/citizen encounters under both the Fourth Amendment and Arti”
2 later decisions quote this exact passage“When we review the ruling of a suppression court, we must ascertain whether its factual findings are supported by the record and whether the inferences and legal conclusions drawn from those facts are reasonable. Where the defendant challenges an adverse ruling of the suppression court, we will consider only the evidence for the prosecution and whatever evidence for the defense that remains uncontradicted in context of the whole record. If there is support on the record, we are bound by the facts as found by the suppression court, and we may reverse that court only if the legal conclusions drawn from these facts are in error. We review the court's legal decisions de novo.”
1 later decision 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.