Commonwealth v. Brown’s Empirical Analysis
1976
Citation profile
2 federal appellate · 47 state decisions
How this case has been cited
Cited by 49 later decisions — most recently July 2009 · most notably Commonwealth v. Melilli (1989), Commonwealth v. Collins (2008)
2 federal appellate · 47 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 · Barker v. Wingo · Mapp v. Ohio · Stovall v. Denno · Johnson v. State of New Jersey
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“... where the prosecution can establish that the challenged evidence would have come to its attention from an independent source free of the taint, there is not the type of exploitation of the illegality that requires the imposition of the rule of exclusion. Restated, where the evidence obtained as the result of illegal police activity would have been discovered in the course of a lawfully conducted investigation, no purpose is served in applying the exclusionary rule. ♦ * * * * # “... it is well established that the fruit of unlawful evidence may nevertheless be admitted if the government demonstrates that the evidence would have come to its attention from an independent source____””
3 later decisions quote this exact passage · from the majority““Appellant argues that the prospective application of Rule 1100 is applicable only to original trials and does not apply to paragraph (e) which pertains to retrials. This argument is premised upon the fact that paragraphs (a) (1) and (a) (2) of the Rule expressly set forth the effective dates of their operation and paragraph (e) fails to contain such a declaration. The argument fails however to recognize the clear intention that the entire Rule was only to be given prospective application. The accompanying explanatory note and the comment to the Rule both expressly provide that the provisions of the Rule should be effective prospectively from the date of the adoption of the Rule, June 8, 1978. See, also, Commonwealth v. Bailey, 463 Pa. 354, 361, n. 6 , 344 A.2d 869, 873, n. 6 (1975); Commonwealth v. Lee, 460 Pa. 374, 379, n. 2 , 333 A.2d 773, 776, n. 2 (1975); Commonwealth v. Roundtree, 458 Pa. 351, 355, n. 6 , 326 A.2d 285, 287, n. 6 (1974).” (Emphasis added).”
1 later decision quote this exact passage · from the majority“The exclusionary rule originated to deter unlawful police practices by depriving law enforcement officials of the benefits derived from using unlawfully obtained information. [Citations omitted.] Where, however, the admission of the proffered evidence does not represent an exploitation of the unlawful police practices the exclusion of relevant testimony would serve only to frustrate the objectives of the adjudicative process without providing any enhancement of that process . .”
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.