454 Pa. Super. 169 - Commonwealth v. Graham’s Empirical Analysis
1996
Citation profile
16 state decisions
How this case has been cited
Cited by 16 later decisions — most recently November 2017
16 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 Terry v. Ohio · Sibron v. State of New York Peters · United States v. Brignoni-Ponce · Minnesota v. Dickerson · Ybarra v. Illinois
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In light of the extreme risks facing lawmen in performing arrests, it will always be reasonable for officers to take some actions to insure their safety concerning companions of arrestees. To find otherwise, would be equivalent to turning a blind eye to reality and declaring open season on our protectors of the peace. Consequently, it is inherently reasonable for a law enforcement officer to briefly detain and direct the movement of an arrestee’s companion, regardless of whether reasonable suspicion exists that the companion is involved in criminal activity. Such minimal intrusion upon the companion’s federal and state constitutional rights are clearly outweighed by the need to extinguish the risks otherwise posed to the lawman’s well-being. Accordingly, the first prong of the “stop and frisk” test is a nullity in cases involving an arrestee’s companion.”
1 later decision quote this exact passage“`We think that Terry recognizes and common sense dictates that the legality of such a limited intrusion into a citizen's personal privacy extends to a criminal's companions at the time of arrest. It is inconceivable that a police officer effecting a lawful arrest of an occupant of a vehicle must expose himself to a shot in the back from [the suspect's] associate because he cannot, on the spot, make a nice distinction between whether the other is a companion in crime or a social acquaintance.'”
1 later decision quote this exact passagee.g. Commonwealth v. Kue
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.