United States v. Thomas’s Empirical Analysis
429 F.3d 282 · 2005
Citation profile
26 federal appellate · 3 district · 16 state decisions
How this case has been cited
Cited by 60 later decisions — most recently October 2025 · most notably United States v. Pruitt (2006), United States v. Archibald (2009)
26 federal appellate · 3 district · 16 state decisions — followed in 14 states
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) · 18 U.S.C. § 924
Relies on United States v. Booker · Payton v. New York · Ornelas v. United States · Maryland v. Buie · United States v. Terry
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“more likely ... that the Supreme Court in Payton used a phrase other than 'probable cause' because it meant something other than 'probable cause.' " Id. (quoting United States v. Thomas , 429 F.3d 282 , 286 (D.C. Cir. 2005) ). Vasquez-Algarin recognized the Valdez court's concern that requiring "actual knowledge”
3 later decisions quote this exact passage“The safety of the officers, not the percentage of the home searched, is the relevant criterion.... If an apartment is small enough that all of it “immediately adjoin[s] the place of arrest” and all of it constitutes a space or spaces “from which an attack could be immediately launched,” then the entire apartment is subject to a limited sweep of spaces where a person may be found.”
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.