2011 Pa. Super. 24 - Commonwealth v. Barnes’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. “[l]iterally read, the statute in question does not make it illegal to provide to a law enforcement authority false information as to one's identity unless and until one is first apprised that he is the subject of an official investigation of a violation of law .”

   3 later decisions quote this exact passage
   e.g. Com. of Pa. v. Kitchen · 2011 Pa. Super. 215 - Commonwealth v. Durr

2. “A person commits an offense if he furnishes law enforcement authorities with false information about his identity after being informed by a law enforcement officer who is in uniform or who has identified himself as a law enforcement officer that the person is the subject of an official investigation of a violation of law.”

   2 later decisions quote this exact passage
   e.g. Com. of Pa. v. Kitchen · In the Interest of D.S.

3. “The Commonwealth further suggests that the circumstances surrounding the traffic stop provided Officer Reeder grounds for an official investigation for a violation of law. The Commonwealth cites the presence of the air fresheners, which are recognized as useful in masking the odor of narcotics, the high crime area, and the fact that neither the driver nor [Barnes] could produce any actual identification. Assuming, for purposes of this discussion, that the circumstances of the stop provided grounds for an investigative detention, we would agree that the statute would be violated by the provision of false information after being provided proper notice. However, the stumbling block to the Commonwealth's argument is Officer Reeder's admission that the investigation he referenced in notifying [Barnes] that he was now the subject of an official investigation was the failure to provide truthful information. Officer Reeder was asked, "So your official investigation was involving that he was giving you a false name?" To this question, Officer Reeder replied, "Yes, after the second time." Going back to our initial point of discussion, if [Barnes] was not yet under official investigation for a violation of law when asked for his name and DOB, the provision of false information was not a violation of law. Thus, that failure to provide true information cannot constitute the basis for the official investigation of a violation of law. Officer Reeder may very well have been investigating [Ba”

   1 later decision quote this exact passage
   e.g. Com. of Pa. v. Kitchen