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← 356 Ark. 507 - Sims v. State

Sims v. State’s Empirical Analysis

2004

Citation profile

98
cited by 98 later decisions
3
states following
April 2025
most recently cited

98 state decisions

How this case has been cited

Cited by 98 later decisions — most recently April 2025 · most notably Yarbrough v. State (2007), Malone v. State (2005)

98 state decisions

520200420102020decided

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

Relies on Beck v. State of Ohio · Florida v. Bostick · United States v. Place · United States v. Wood · Davis v. State

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

  1. “A law enforcement officer lawfully present in any place may, in the performance of his duties, stop and detain any person who he reasonably suspects is committing, has committed, or is about to commit (1) a felony, or (2) a misdemeanor involving danger of forcible injury to persons or of appropriation of or damage to property, if such action is reasonably necessary either to obtain or verify the identification of the person or to determine the lawfulness of his conduct. An officer acting under this rule may require the person to remain in or near such place in the officer’s presence for a period of not more than fifteen (15) minutes or for such time as is reasonable under the circumstances. At the end of such period the person detained shall be released without further restraint, or arrested and charged with an offense.”
    5 later decisions quote this exact passage
  2. “It is true that, as part of a valid traffic stop, a police officer may detain a traffic offender while the officer completes certain routine tasks, such as computerized checks of the vehicle’s registration and the driver’s license and criminal history, and the writing up of a citation or warning. See Laime, 347 Ark. at 157 -58 (citing United States v. Carrazco, 91 F.3d 65 (8th Cir. 1996)). During this process, the officer may ask the motorist routine questions such as his destination, the purpose of the trip, or whether the officer may search the vehicle, and he may act on whatever information is volunteered. Id. at 158 . However, after those routine checks are completed, unless the officer has a reasonably articulable suspicion for believing that criminal activity is afoot, continued detention of the driver can become unreasonable. See United States v. Beck, 140 F.3d 1129 (8th Cir. 1998) (citing United States v. Mesa, 62 F.3d 159 (6th Cir. 1995)); United States v. $404,905.00 in US. Currency, 182 F.3d 643 (8th Cir. 1999). In Mesa, supra, the Sixth Circuit stated that “[o]nce the purposes of the initial traffic stop were completed, there is no doubt that the officer could not further detain the vehicle or its occupants unless something that occurred during the traffic stop generated the necessary reasonable suspicion to justify a further detention.” Mesa, 62 F.3d at 162 . Similarly, the Tenth Circuit has held that, in the absence of a reasonable, articulable suspicion of some”
    1 later decision quote this exact passage
  3. “[A]s part of a valid traffic stop, a police officer may detain a traffic offender while the officer completes certain routine tasks, such as computerized checks of the vehicle’s registration, the driver’s license and criminal history, and the writing up of a citation or warning. During this process, the officer may ask the motorist routine questions such as his destination, the purpose of the trip, or whether the officer may search the vehicle, and he may act on whatever information is volunteered.”
    1 later decision quote this exact passage

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.