State v. Phelps’s Empirical Analysis
1979
Citation profile
10 state decisions
How this case has been cited
Cited by 10 later decisions — most recently May 2001
10 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 Mapp v. Ohio · Chimel v. California · Schmerber v. State of California · Stoner v. California · Cupp v. Murphy
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“When an arrest is made, it is reasonable for the arresting officer to search the person arrested in order to remove any weapons that the latter might seek to use in order to resist arrest or effect his escape. Otherwise, the officer’s safety might well be endangered, and the arrest itself frustrated. In addition, it is entirely reasonable for the arresting officer to search for and seize any evidence on the arrestee’s person in order to prevent its concealment or destruction. And the area into which an arrestee might reach in order to grab a weapon or evidentiary items must, of course, be governed by a like rule. A gun on a table or in a drawer in front of one who is arrested can be as dangerous to the arresting officer as one concealed in the clothing of the person arrested. There is ample justification, therefore, for a search of the arrestee’s person and the area “within his immediate control” — construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence.”
1 later decision quote this exact passagee.g. State v. Lanctot“The fourth and fourteenth Amendments to the United States Constitution and Article I, Section [8] of the North Dakota Constitution prohibit unreasonable searches and seizures. The guiding ‘principle behind these prohibitions is to safeguard personal privacy and dignity against unwarranted intrusions by the State. To realize this principle, all evidence obtained in searches and seizures which transgress the commandments of the fourth amendment to the federal constitution has been made inadmissible in state courts by the United States Supreme Court.”
1 later decision quote this exact passagee.g. State v. Herrick
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.