State v. Payano-Roman’s Empirical Analysis
2006
Citation profile
2 federal appellate · 34 state decisions
How this case has been cited
Cited by 36 later decisions — most recently February 2026 · most notably State v. Post (2007), 2009 WI App 82 - State v. Berggren (2009)
2 federal appellate · 34 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 Chimel v. California · Schmerber v. State of California · Rochin v. People of California · Ker v. State of California · Cady v. Dombrowski
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'(1) the police may not initiate, encourage or participate in the private entity's search; (2) the private entity must engage in the activity to further its own ends or purpose; and (3) the private entity must not conduct the search for the purpose of assisting governmental efforts.'”
3 later decisions quote this exact passage“A lawful arrest gives rise to heightened concerns that may justify a warrantless search, including the need to discover and preserve evidence.”
3 later decisions quote this exact passage“Once the State raises the issue, asserting that a search is a private search, the defendant has the burden of proving by a preponderance of the evidence that government involvement in a search or seizure brought it within the protections of the Fourth Amendment.”
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.