Phelps v. Coy’s Empirical Analysis
286 F.3d 295 · 2002
Citation profile
61 federal appellate · 2 district ·
How this case has been cited
Cited by 164 later decisions (1 by the Supreme Court) — most recently January 2025 · most notably Champion v. Outlook Nashville, Inc. (2004), Estate of Carter v. City of Detroit (2005)
61 federal appellate · 2 district ·
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 Graham v. Connor · Duncan v. Walker · SAUCIER v. KATZ Et Al. · Johnson v. Jones · Whitley v. Albers
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 164 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We have explicitly held that the Fourth Amendment reasonableness standard governs throughout the seizure of a person: “[T]he seizure that occurs when a person is arrested continues throughout the time the person remains in the custody of the arresting officers.” McDowell v. Rogers, 863 F.2d 1302 , 1306 (6th Cir.1988). In Cox v. Treadway, 75 F.3d 230 , 241 (6th Cir.1996), Judge Ryan, writing for the court, stated that the constitutional analysis does not instantly change the moment a suspect is subdued by the police and that “creating a different Fourth Amendment standard applicable to the use of force in a post-arrest situation than is applicable to pre-arrest conduct [would introduce] a distinction in meaning of the Fourth Amendment that is found nowhere in its language.” While the continuing seizure rule is not universally accepted in other circuits, see Fontana v. Haskin, 262 F.3d 871 , 879-80 & n. 5 (9th Cir.2001) (detailing circuit split on this issue), it is the law in this circuit and has been since McDowell.”
1 later decision quote this exact passage · from the majoritye.g. Aldini v. Johnson“We do not believe that the Fourth Amendment provides an appropriate constitutional basis for protecting against deliberate official uses of force occurring, as in this case, after the incidents of arrest are completed, after the plaintiff has been released from the arresting officer’s custody, and after the plaintiff has been in detention awaiting trial for a significant period of time.”
1 later decision quote this exact passage · from the majority“the qualified immunity doctrine exists partly to protect officials from having to stand trial; a defendant wrongly forced to go to trial loses the benefit of the immunity even if he or she is exonerated after trial; therefore, the order cannot effectively be reviewed after trial and is considered *517 final.”
1 later decision quote this exact passage · from the majoritye.g. Harrison v. Ash
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.