United States v. Thomas’s Empirical Analysis
372 F.3d 1173 · 2004
Citation profile
16 federal appellate · 6 district · 1 state decisions
How this case has been cited
Cited by 32 later decisions — most recently April 2025 · most notably United States v. Angelos (2006), United States v. Kimoana (2004)
16 federal appellate · 6 district · 1 state decisions
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. § 922 (Brady Handgun Violence Prevention Act)
Relies on Coolidge v. New Hampshire · Warden, Maryland Penitentiary v. Hayden · Sedillo v. United States · Minnesota v. Olson · Minnesota, v. Wayne Thomas Carter
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) the officer was lawfully in a position from which the object seized was in plain view, (2) the object’s incriminating character was immediately apparent (i.e., there was probable cause to believe it was contraband or evidence of a crime), and (3) the officer had a lawful right of access to the object.”
2 later decisions quote this exact passage · from the majority“(1) the officers must have reasonable grounds to believe that there is an immediate need to protect the lives or safety of themselves or others; (2) the search must not be motivated by an intent to arrest or seize evidence; and (3) there must be some reasonable basis, approaching probable cause, to associate the emergency with the place to be searched.”
1 later decision quote this exact passage · from the majority“faced a situation in which there were firearms inside the home, it was unclear how many people were inside the home, and the circumstances gave rise to a reasonable fear that the firearms might be used against the officers or others.”
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.