United States v. Edwards’s Empirical Analysis
441 F.2d 749 · 1971
Citation profile
53 federal appellate · 1 district · 36 state decisions
How this case has been cited
Cited by 105 later decisions — most recently March 2021 · most notably United States v. Colbert (1973), United States v. Bell (1972)
53 federal appellate · 1 district · 36 state decisions — followed in 22 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 26 U.S.C. § 5205 · 26 U.S.C. § 5613
Relies on Terry v. Ohio · Katz v. United States · Carroll v. United States · Mapp v. Ohio · Brinegar 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 105 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A bilateral approach to this search reveals legality on two grounds. First, considering the case from the defendant’s point of view, we find that by abandonment he had no Fourth Amendment right to be secure against this kind of search, at the time it was made. Second, from the Government’s standpoint, we find that the search reasonably balanced the interest of the state with the defendant’s civil rights in this situation. “Defendant’s right to Fourth Amendment protection came to an end when he abandoned his car to the police, on a public highway, with engine running, keys in the ignition, lights on, and fled on foot. At that point defendant could have no reasonable expectation of privacy with respect to his automobile.” 441 F.2d at 751 .”
5 later decisions quote this exact passage · from the majority““It is interesting to compare the cases where an owner may give another such complete and unrestricted freedom over his property that he will be held to have accepted the risk that the person will consent to a search, thus losing his right to privacy. [Citations omitted.] The circumstances here were not sufficiently compelling to make involuntary the choice to abandon his car to the pursuing officer. Having done so, Edwards accepted the risk that the officer would search the car, thus losing his right to constitutional protection.” 441 F.2d at 752-53 .”
2 later decisions quote this exact passage · from the majority““The record discloses essentially a combination of four factors: (1) The initial speeding which gave legality to the chase by the state trooper; (2) the increasing speed to 90-110 miles per hour in an obvious effort to outrun the police and escape arrest; (3) the abandonment of the automobile on the public right-of-way, partly on and partly off the pavement with the lights on and motor running, with the obvious knowledge that it would come into possession of the law enforcement officers; and (4) the flight from the scene on foot into the night and remaining at large. “Confronted with this situation, it would have been unreasonable not to make some inspection of the automobile. The key being readily available, the trunk could be inspected as a part of the car within the bounds of reason. This inspection was properly a part of the on-the-scene investigation that the officer was duty bound to carry out.” 441 F.2d at 754 .”
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.