Steele v. United States No. 1’s Empirical Analysis
267 U.S. 498 · 1925
Citation profile
501 federal appellate · 107 district · 583 state decisions
How this case has been cited
Cited by 1,493 later decisions (50 by the Supreme Court) — most recently February 2025 · most notably United States v. Leon (1984), Brinegar v. United States (1949)
501 federal appellate · 107 district · 583 state decisions — followed in 47 states
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 Carroll v. United States · Rose v. State · United States v. Borkowski · Elrod v. Moss
Cited together with United States v. Ventresca · Marron v. United States · Illinois v. Gates · Maryland v. Garrison · United States v. Leon
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 1,493 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is enough if the description is such that the officer with a search warrant can, with reasonable effort ascertain and identify the place intended.”
56 later decisions quote this exact passage · from the majority“The building searched was a four-story building in New York City on the south side of West 46th Street, with a sign on it: “Indian Head Auto Truck Service— Indian Head Storage Warehouse, No. 609 and 611.” It was all under lease to Steele. It was entered by three entrances from the street, one on the 609 side, which is used, and which leads to a staircase running up to the four floors. On the 611 side there is another staircase of a similar character, which is closed, and in the middle of the building is an automobile entrance from the street into a garage, and opposite to the entrance on the south side is an elevator reaching to the four stories, of sufficient size to take up a Ford machine. There is no partition between 611 and 609 on the ground or garage floor, and there were only partial partitions above, and none which prevented access to the elevator on any floor from either the 609 or 611 side. The evidence left no doubt that, though the building had two numbers, the garage business covering the whole first floor and the storage business above were of such a character and so related to the elevator that there was no real division in fact or in use of the building into separate halves. The places searched and in which the liquor was found were all rooms connected with the garage by the elevator.”
3 later decisions quote this exact passage · from the majority“particularly describing the place to be searched”
3 later decisions quote this exact passage · from the majority
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.