34 Va. App. 45 - Piggott v. Commonwealth’s Empirical Analysis

Citation profile

18 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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[T]he consensual aspect of the encounter ceased when [the detective] retained Piggott’s identification while he ran a warrant check. A reasonable person in Piggott’s circumstances would not have believed that he could terminate the encounter and walk away. By retaining Piggott’s identification, [the detective] implicitly commanded Piggott to stay. Thus, for Fourth Amendment purposes, Piggott was then “seized” by [the detective].”

   2 later decisions quote this exact passage
   e.g. Commonwealth v. Parker · 945 So. 2d 1174 - Golphin v. State

2. “[The officer's] request for [the defendant's] identification initiated a consensual encounter and implicated no Fourth Amerdment interest. However, the consensual aspect of the encounter ceased when [the officer] retained [the defendant's] identification while he ran a warrant check. A reasonable person in [the defendant's] cireumstances would not have believed that he could terminate the encounter and walk away.”

   1 later decision quote this exact passage
   e.g. People v. Jackson