268 Pa. Super. 259 - Commonwealth v. Ryan’s Empirical Analysis
1979
Citation profile
25 state decisions
How this case has been cited
Cited by 27 later decisions — most recently August 2025 · most notably 300 Pa. Super. 156 - Commonwealth v. Ryan (1982), 295 Pa. Super. 72 - Commonwealth v. Simmons (1982)
25 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 Commonwealth v. Hall · Commonwealth v. D'ANGELO · 245 Pa. Super. 487 - Commonwealth v. Jones · Commonwealth v. Dixon · 250 Pa. Super. 436 - Commonwealth v. Smith
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the instant case the defendant was prevented from exercising his right to test the veracity of the information contained in the search warrant. The burden is on the Commonwealth to establish the validity of the search warrant and the burden is not carried by merely introducing the search warrant and affidavit with no supporting testimony because then the only way for the defendant to challenge the veracity of the information is to call witnesses himself and this effectively shifts onto him the burden of disproving the veracity of the information, an almost impossible burden. If the procedure followed by the Commonwealth in this case were upheld then policemen could recite in an affidavit as probable cause for the issuance of a search warrant any and all statements which they felt were of help in obtaining the warrant, irrespective of the truth or veracity of those statements, their legality or illegality, or constitutionality or unconstitutionality, realizing that such statements would be insulated from defendant’s right of cross-examination since the Commonwealth did not have to call witnesses who would be subject to cross-examination to establish the facts necessary to support the issuance of the search warrant. Therefore, we must hold that the Commonwealth failed to carry its burden of proof at the suppression hearing. To rule otherwise would permit police in every case to exaggerate or to expand on the facts given to the issuing authority merely for the purpose of meet”
2 later decisions quote this exact passage“[T]he allegation of “5 arrests and 3 convictions” resulting from an unnamed informant’s earlier information is an assertion that is impossible for a defendant to explore prior to the suppression hearing, and is clearly a proper subject for inquiry there____ Indeed, the only existing method to effectively probe the veracity of the assertion is to allow a defendant meaningful cross-examination of the police officer-affiant at the suppression hearing____ It must be concluded that appellant at the suppression hearing should have been afforded the opportunity through “the traditional safeguard” of cross-examination, to test the truthfulness of the recitals in the warrant alleging the informant’s previous reliability.”
1 later decision quote this exact passage“At a suppression hearing, the Commonwealth has the burden of going forward with the evidence and of establishing that the challenged evidence was not obtained in violation of the defendant's rights.”
1 later decision quote this exact passage · from the dissent
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.