State v. Smith’s Empirical Analysis
2005
Citation profile
28 state decisions
How this case has been cited
Cited by 28 later decisions — most recently January 2023 · most notably State v. Graf (2006), State v. Addai (2010)
28 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 United States v. Melendez-Garcia · 137 Ill. 2d 382 - People v. Murray · 218 Wis. 2d 180 - State v. Phillips · United States v. Chavez-Villarreal · Guardiola v. State
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[The] voluntary consent to a search, preceded by an illegal police action, does not automatically purge the taint of an illegal detention. A second inquiry is necessary to determine whether the taint is purged from the evidence seized during the allegedly unlawful detention by considering the following factors: (1) the temporal proximity between the illegal search or seizure and the consent; (2) the presence of intervening circumstances; and (3) the purpose and flagrancy of the official misconduct. If the consent is not purged of the unlawful detention, it is still fruit of the poisonous tree.”
2 later decisions quote this exact passage“We do not require an officer to isolate single factors which signal a potential violation of the law; but instead, “officers are to assess the situation as it unfolds and, based upon inferences and deductions drawn from their experience and training, make the determination whether all of the circumstances viewed together create a reasonable suspicion of potential criminal activity.” When assessing reasonableness, we consider inferences and deductions an investigating officer would make which may elude a layperson.”
1 later decision quote this exact passagee.g. State v. Torkelsen“In order to apply the inevitable-discovery theory, the State must meet a two-part test. First, use of the doctrine is permitted only when the police have not acted in bad faith to accelerate the discovery of the evidence in question. Second, the State must prove that the evidence would have been found without the unlawful activity and must show how the discovery of the evidence would have occurred.”
1 later decision quote this exact passagee.g. State v. Stewart
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.