Commonwealth v. McLaughlin’s Empirical Analysis

Citation profile

39 state decisions

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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““In Pennsylvania ‘custodial interrogation’ has been interpreted to mean either questioning . . . ‘while in custody or while the object of an investigation of which [the defendant] is the focus, . . . ’ Commonwealth v. Feldman, 432 Pa. 428, 432-33 , 248 A.2d 1, 3 (1968) Commonwealth v. D’Nicuola, 448 Pa. 54, 57 , 292 A.2d 333, 335 (1972) (emphasis added). Subsequent to these Pennsylvania cases, the United States Supreme Court in Beckwith v. United States, 425 U.S. 341 , 96 S.Ct. 1612 , 48 L.Ed.2d 1 (1976) explained that the Miranda Court ‘specifically defined “focus,” [of an investigation] for its purposes, as “questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his action in any significant way”.’ ” Commonwealth v. McLaughlin, 475 Pa. 97 , 379 A.2d 1056, 1057-58 (1977).”

   2 later decisions quote this exact passage · from the majority
   e.g. 320 Pa. Super. 304 - Commonwealth v. Markman · 256 Pa. Super. 376 - Commonwealth v. Bodge

2. “In the present case, however, there is no indication that the questioning took place in a context where respondent’s freedom to depart was restricted in any way. He came voluntarily to the police station, where he was immediately informed that he was not under arrest. At the close of a lk hour interview respondent did in fact leave the police station without hindrance. It is clear from these facts that Mathiason was not in custody “or otherwise deprived of his freedom of action in any significant way.” Such a noncustodial situation is not converted to one in which Miranda applies simply because a reviewing court concludes that, even in the absence of any formal arrest or restraint on freedom of movement, the questioning took place in a “coercive environment.” Any interview of one suspected of a crime by a police officer will have coercive aspects to it, simply by virtue of the fact that the police officer is part of a law enforcement system which may ultimately cause the suspect to be charged with a crime. But police officers are not required to administer Miranda warnings to everyone whom they question. Nor is the requirement of warnings to be imposed simply because the questioning takes place in the station house, or because the questioned person is one whom the police suspect. Miranda warnings are required only where there has been such a restriction on a person’s freedom as to render him “in custody.” It was that sort of coercive environment to which Miranda by its terms ”

   1 later decision quote this exact passage · from the majority
   e.g. 320 Pa. Super. 304 - Commonwealth v. Markman

3. “Although by our placing of “object of an investigation” in the disjunctive with the custodial requirement, it might appear as though the Pennsylvania interpretation of when Miranda warnings are required was broader than the United States Supreme Court’s interpretation, an examination of the facts taken with the language of Pennsylvania cases indicates those cases may be interpreted as being harmonious with Beckwith.”

   1 later decision quote this exact passage · from the majority
   e.g. Commonwealth v. Holcomb