District of Columbia v. Little’s Empirical Analysis
339 U.S. 1 · 1950
Citation profile
120 federal appellate · 9 district · 89 state decisions
How this case has been cited
Cited by 282 later decisions (25 by the Supreme Court) — most recently April 2025 · most notably Camara v. Municipal Court of City and County of San Francisco (1967), Kent v. United States (1966)
120 federal appellate · 9 district · 89 state decisions — followed in 18 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.
Appellate journey
reviewedDistrict of Columbia v. Little (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on Rescue Army v. Municipal Court of Los Angeles · Griffin v. United States · District of Columbia v. Little · District of Columbia v. Little
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 282 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“threatened force is not always an indispensable ingredient in the offense of interfering with an officer in the discharge of his duties....”
4 later decisions quote this exact passage · from the majority““In this Court the constitutional arguments have extended far beyond the comparatively narrow issues involved in the particular case. At one extreme the District argues that the Fourth Amendment has no application whatever to inspections and investigations made by health officers; that to preserve the public health, officers may without judicial warrants enter premises, public buildings and private residences at any reasonable hour, with or without the owner’s consent. At the opposite extreme, it is argued that no sanitary inspection can ever be made by health officers without a search warrant, except with a property owner’s consent. Between these two extremes are suggestions that the Fourth Amendment requires search warrants to inspect premises where the object of inspections is to obtain evidence for criminal punishment or where there are conditions imminently dangerous to life and health, but that municipalities and other governing agencies may lawfully provide for general routine inspections at reasonable hours without search, warrants. An impressive array of facts is also presented concerning the uniform practices of agencies of local governments to provide for such general routine inspections in connection with sanitation, plumbing, buildings, etc.””
1 later decision quote this exact passage · from the majoritye.g. Givner v. State““Neither the facts of this case, nor the District law on which the prosecution rests, provide a basis for a sweeping determination of the Fourth Amendment’s application to all these varied types of investigations, inspections and searches. Yet a decision of the constitutional requirement for a search in this particular case might have far-reaching and unexpected implications as to closely related questions not now before us. This is therefore an appropriate case in which to apply our sound general policy against deciding constitutional questions if the record permits final disposition of a cause on non-constitutional grounds.””
1 later decision quote this exact passage · from the majoritye.g. Givner v. State
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.