Bethea v. Commonwealth’s Empirical Analysis

Citation profile

21 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[W]e need not determine whether the de minimis rationale utilized in Mimms is applicable to a passenger in a vehicle when the initial vehicle stop is predicated solely on matters pertaining to the driver. The facts of this case only require the application of the more general principle that Fourth Amendment interests are not violated when a police officer can “point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.””

   2 later decisions quote this exact passage
   e.g. Pryor v. Commonwealth · State v. Wilson

2. “The totality of the circumstances we consider here included a traffic stop in a high-crime area; similar traffic stops by the same officers two days earlier in the same neighborhood where weapons were discovered in a car; Bethea’s actions immediately prior to the stop; Warren’s 22 years of experience and his statements that Bethea’s actions “startled” and “scared” him; and Warren’s concern that Bethea might have weapons in the car. These circumstances constitute “specific and articulable facts” which show that Warren was reasonably concerned for his safety and believed that Bethea might have had access to weapons with which to assault him. These facts justified the intrusion on Bethea’s Fourth Amendment rights that occurred when Warren asked him to get out of the car. The fact that Warren did not immediately pat down or frisk Bethea does not belie Warren’s concern for his own safety, as Bethea contends. Warren stated that he felt safer with Bethea outside the vehicle, not only because of Bethea’s behavior, but also because of his concern that there might be weapons in the car. (Citation omitted.) (Emphasis supplied.)”

   1 later decision quote this exact passage
   e.g. State v. Wilson