State v. Holt’s Empirical Analysis

Citation profile

16 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[Some cases] tend to decide whether an occupant has a reasonable expectation of privacy according to whether there is a door on the stall. In our opinion, that distinction is too simple to adequately protect reasonable expectations of privacy held by persons who use public restrooms. As Katz [ v. United States, 389 U.S. 347 (1967)] made clear, the law may protect a reasonable expectation of less than total privacy, ( i.e., in Katz an expectation of auditory privacy, but not visual privacy). One who chooses to use a doorless stall may desire total privacy, but he cannot reasonably expect it. Rather, he accepts a limited risk of observation as a consequence of the limitations of the physical structure.”

   1 later decision quote this exact passage
   e.g. 48 Wash. App. 583 - State v. Berber

2. “For the Fourth Amendment protects people, not places. What a person knowingly exposes to the public, even in his own home or office, is not a subject of Fourth Amendment protection ... But what he seeks to preserve as private even in an area accessible to the public, may be constitutionally protected. (Citations omitted.) (Emphasis added.)”

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

3. “The expectation of privacy a person has when he enters a restroom is reasonable and is not diminished or destroyed because the toilet stall being used lacks a door.”

   1 later decision quote this exact passage
   e.g. 48 Wash. App. 583 - State v. Berber