2017 Pa. Super. 100 - Commonwealth v. Lukach’s Empirical Analysis

Citation profile

3 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Berghuis , 560 U.S. at 381 , 130 S.Ct. 2250 . As aptly summarized by the Superior Court below, the defendant [in Berghuis ] was silent during the first two hours and forty-five minutes of a three-hour interrogation. Berghuis , [ 560 U.S. at 374 -76 , 130 S.Ct. 2250 ]. He did not state that he wished to remain silent, that he did not want to talk to the police, or that he wanted an attorney. Id. However, towards the end of the interrogation, a police officer asked defendant whether he prayed to God to forgive him for the shooting, to which the defendant responded,”

   1 later decision quote this exact passage
   e.g. Commonwealth, Aplt. v. Lukach, J.

2. “[ Id. at 376 , 130 S.Ct. 2250 ]. The defendant refused to sign a written confession and argued that his statement to detectives should have been suppressed because he had invoked his right to remain silent. Id. Lukach , 163 A.3d at 1008 . In holding Berghuis failed to unambiguously invoke his right to remain silent, the High Court explained he”

   1 later decision quote this exact passage
   e.g. Commonwealth, Aplt. v. Lukach, J.

3. “would lead a reasonable police officer, in those circumstances, to understand [it] to be a request to remain silent.”

   1 later decision quote this exact passage
   e.g. Commonwealth, Aplt. v. Lukach, J.