Commonwealth v. Bess’s Empirical Analysis
1978
Citation profile
27 state decisions
How this case has been cited
Cited by 27 later decisions — most recently April 1991 · most notably Commonwealth v. Stanley (1982), Commonwealth v. Scarborough (1980)
27 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 Chimel v. California · United States v. Chadwick · Commonwealth v. Futch · Commonwealth v. Davis · Commonwealth v. London
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Incident to a lawful arrest, police officers may conduct a warrantless search of the person arrested and the area within that person's immediate control in order to remove any weapons that might be used to facilitate escape or resist arrest, and to prevent destruction of evidence. Chimel v. California [ 395 U.S. 752 , 89 S.Ct. 2034 , 23 L.Ed.2d 685 ], supra ; Commonwealth v. Davis, 466 Pa. 102 , 351 A.2d 642 (1976). Whether an item has been properly seized pursuant to a search incident to arrest depends upon the facts of each case. The central question is whether the area searched is one "within which [the arrested person] might gain possession of a weapon or destructible evidence". Chimel v. California, supra [395 U.S.] at 763, 89 S.Ct. at 2040 .”
1 later decision quote this exact passage · from the majority“within which [the arrested person] might gain possession of a weapon or destructible evidence”
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.