United States v. Crain’s Empirical Analysis
33 F.3d 480 · 1994
Citation profile
45 federal appellate · 5 district · 23 state decisions
How this case has been cited
Cited by 100 later decisions — most recently June 2024 · most notably United States v. McRae (1996), United States v. Purcell (2001)
45 federal appellate · 5 district · 23 state decisions — followed in 13 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
Applies 18 U.S.C. § 2 · 21 U.S.C. § 841 (§ 401 of the Controlled Substances Act) · 21 U.S.C. § 846 (§ 406 of the Controlled Substances Act)
Relies on Jackson v. Virginia · Terry v. Ohio · Pinkerton v. United States · Florida v. Jimeno · Weatherford v. Bursey
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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In an attempt to prove constructive possession, the government emphasizes the fact that the cocaine was found under the driver’s seat where Crain had been sitting, and it contends that because Crain was driving the vehicle, he had control over the vehicle and therefore the drugs. However, we have held that when two or more people are occupying a place, a defendant’s control over the place is not by itself enough to establish constructive possession of contraband found there_We are especially reluctant to infer constructive possession of contraband by one occupant when there is evidence in the record explicitly linking the contraband to another occupant.”
2 later decisions quote this exact passage · from the majoritye.g. Burwell v. United States · In Re RG“[W]hen questioning takes place while officers are waiting for the results of a computer check — and therefore does not extend the duration of the stop — • the questioning does not violate Terry.”
2 later decisions quote this exact passage · from the majority“To prove possession of a controlled substance with intent to distribute, the government must prove beyond a reasonable doubt the defendants possession of the illegal substance, knowledge, and intent to distribute. The necessary knowledge and intent can be proved by circumstantial evidence.”
1 later decision 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.