Commonwealth v. Benoit’s Empirical Analysis
1981
Citation profile
3 federal appellate · 3 district · 66 state decisions
How this case has been cited
Cited by 74 later decisions — most recently April 2019 · most notably Commonwealth v. Yesilciman (1990), Commonwealth v. Matchett (1982)
3 federal appellate · 3 district · 66 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
Relies on Wong Sun v. United States · Brown v. Illinois · Massiah v. United States · South Dakota v. Opperman · Brewer v. Williams
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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The [United States] Supreme Court has recognized two exceptions to the fruit of the poisonous tree doctrine. Evidence is not excluded under the doctrine if (1) the government obtained it through an independent source, ... or (2) the ‘connection [between the improper conduct and the derivative evidence has] become so attenuated as to dissipate the taint.’ . . . These exceptions allow removal of the taint if the government can demonstrate that the improper official conduct was not a sine qua non or ‘but for’ cause of the discovery of the evidence.””
1 later decision quote this exact passage“The significant difference between the tests is that under the independent source rule the inquiry is whether the government did in fact acquire certain evidence through an untainted source, while under the inevitable discovery rule the inquiry is whether evidence found because of a constitutional violation would inevitably have been discovered lawfully.”
1 later decision quote this exact passage · from the dissent“It is possible to surmise that the police may have failed to obtain a warrant in reliance on a mistaken belief that they had obtained a valid consent to search from the defendant”
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.