Washington v. Chrisman’s Empirical Analysis
1982
Citation profile
154 federal appellate · 29 district · 375 state decisions
How this case has been cited
Cited by 681 later decisions (12 by the Supreme Court) — most recently August 2025 · most notably Superintendent Massachusetts Correctional Institution Walpole v. Hill (1985), Ohio v. Robinette (1996)
154 federal appellate · 29 district · 375 state decisions — followed in 39 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
Relies on Miranda v. State of Arizona Vignera · Katz v. United States · Carroll v. United States · Payton v. New York · Coolidge v. New Hampshire
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 681 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Every arrest must be presumed to present a risk of danger to the arresting officer. There is no way for an officer to predict reliably how a particular subject will react to arrest or the degree of the potential danger. Moreover, the possibility that an arrested person will attempt to escape if not properly supervised is obvious.”
39 later decisions quote this exact passage“Indeed, were the rule otherwise, it is doubtful that an arrested person would ever be permitted to return to his residence, no matter how legitimate the reason for doing so. Such a rule would impose far greater restrictions on the personal liberty of arrested individuals than those occasioned here.”
2 later decisions quote this exact passage · from the dissent“As Judge Moylan points out in his article on the doctrine, “The hardest conceptual problem attending the plain view doctrine is to grasp that it is not a universal statement of the right of a policeman to seize after seeing something in open view; it is rather a limited statement of that right in one of several instances— following a valid intrusion.” Moylan, The Plain View Doctrine, 26 Mercer L.Rev. 1047, 1096. Moylan isolates two types of observations of items in open view which are not covered by the plain-view doctrine. The first is the nonintrusive situation, where the police see seizable evidence in open view in a constitutionally nonprotected area, e.g., an open field. In this situation if the police seize the evidence they do it not by virtue of the plain-view doctrine, but because “there is no constitutional provision to gainsay the seizure.” Id., p. 1097. The second situation is the preintrusive situation, where police stand on the outside of a constitutionally protected area and look in and see seizable items in open view. In this situation the police may seize the evidence without a warrant only if there is “an additional legal predicate for the intrusion necessary to effect a seizure.” Id., p. 1100.”
1 later decision quote this exact passage · from the dissente.g. State v. Griffin
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.