State v. Grayson’s Empirical Analysis

Citation profile

35 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[L]egal determinations of reasonable suspicion ... are reviewed de novo.”

   3 later decisions quote this exact passage
   e.g. State of Missouri v. James Earl Lee · State v. Hughes

2. “The Fourth Amendment protects the right of citizens to be free from unreasonable searches and seizures, and it applies to state actors through the Fourteenth Amendment. Article I, section 15 of the Missouri Constitution is coextensive with the Fourth Amendment; consequently, the same analysis applies under both provisions.”

   2 later decisions quote this exact passage · from the concurrence
   e.g. State v. Perry · State v. Williams

3. “As the United States Supreme Court noted in Nix v. Williams, 467 U.S. 431 , 104 S.Ct. 2501 , 81 L.Ed.2d 377 (1984)], the purpose of the exclusionary rule is to ensure that “the prosecution is not to be put in a better position than it would have been if no illegality had transpired.” Id. at 443 , 104 S.Ct. 2501 . Conversely, the reason for the exceptions is to ensure that “the prosecution is not put in a worse position simply because of some earlier police error or misconduct.” Id. Here, Officer Lambert obtained the bag of methamphetamine by taking advantage of the direct chain of events arising from the initial illegality perpetrated on Mr. Gray-son. Had Mr. Grayson not been detained while driving innocently and further detained after Officer Lambert ascertained that he was not Terry Reed, then Officer Lambert never would have been in a position to arrest Mr. Grayson and later discover the bag of methamphetamine while inspecting the patrol car’s backseat after transporting Mr. Grayson to jail. While the state may have properly arrested Mr. Grayson on the outstanding warrant at some point, it is not the arrest on the warrant but the conviction of possession of methamphetamine found in the patrol car some time after the arrest that is objected to here. Here, the “prosecution was put in a better position than it would have been if no illegality had transpired.” Nix, 467 U.S. at 443 , 104 S.Ct. 2501 .”

   1 later decision quote this exact passage · from the concurrence
   e.g. 230 Md. App. 640 - State v. Sizer