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← 376 So. 2d 773 - Harris v. State

376 So. 2d 773 - Harris v. State’s Empirical Analysis

1979

Citation profile

27
cited by 27 later decisions
2
states following
February 2016
most recently cited

27 state decisions

How this case has been cited

Cited by 27 later decisions — most recently February 2016 · most notably 534 So. 2d 329 - Hooks v. State (1987), 397 So. 2d 217 - Terry v. State (1981)

27 state decisions

16019791980199020002010decided

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 Miranda v. State of Arizona Vignera · Schneckloth v. Bustamonte · Escobedo v. Illinois · Oregon v. Mathiason · Patterson v. United States

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

  1. “" Miranda is limited to custodial interrogations only. Custodial interrogation is defined as 'questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.' Miranda , 86 S.Ct. at 1612 . This is what was meant in Escobedo v. Illinois , 378 U.S. 478 , 84 S.Ct. 1758 , 12 L.Ed.2d 977 (1964), by reference to an investigation which had 'focused' on the accused. Miranda , 86 S.Ct. at 1612 , fn. 4. "The Miranda warnings are not required simply because the questioned person is one whom the police suspect or one on whom the investigation has focused. Oregon v. Mathiason , 429 U.S. 492 , 97 S.Ct. 711 , 50 L.Ed.2d 714 (1977); Beckwith v. United States , 425 U.S. 341 , 96 S.Ct. 1612 , 48 L.Ed.2d 1 (1976); Malone v. State , 361 So.2d 674 (Ala.Cr.App.), cert. denied, 361 So.2d 691 (Ala. 1978). The '[c]riteria used to determine the necessity of Miranda safeguards include: probable cause to arrest, subjective intent of the police, subjective belief of the defendant, and focus of the investigation. Especially important is whether the focus of the investigation had finally been centered on the accused.' Harrison v. State , 358 So.2d 759 , 761 (Ala.Cr.App. 1977), reversed on other grounds, 358 So.2d 763 (Ala. 1978). While investigative focus is especially significant, it is custody and not focus which marks the point at which the Miranda warnings become mandatory. Mathiason , supra."”
    6 later decisions quote this exact passage
  2. “"`The Miranda warnings are not required simply because the questioned person is one whom the police suspect or one on whom the investigation has focused. Oregon v. Mathiason , 429 U.S. 492 , 97 S.Ct. 711 , 50 L.Ed.2d 714 (1977); Beckwith v. United States , 425 U.S. 341 , 96 S.Ct. 1612 , 48 L.Ed.2d 1 (1977); Malone v. State , 361 So.2d 671 (Ala.Cr.App.), cert. denied, 361 So.2d 691 (Ala. 1978). The "[c]riteria used to determine the necessity of Miranda safeguards include: probable cause to arrest, subjective intent of the police, subjective belief of the defendant, and focus of the investigation. Especially important is whether the focus of the investigation had finally been centered on the accused." Harrison v. State , 358 So.2d 759 , 761 (Ala.Cr.App. 1977), reversed on other grounds, 358 So.2d 763 (Ala. 1978). While investigative focus is especially significant, it is custody and not focus which marks the point at which the Miranda warnings become mandatory. Mathiason, supra.'"”
    4 later decisions quote this exact passage
  3. “focus in and of itself is not the determinative question in determining the existence of custody.”
    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.