Commonwealth v. Holzer’s Empirical Analysis
1978
Citation profile
232 state decisions
How this case has been cited
Cited by 234 later decisions (2 by the Supreme Court) — most recently December 2025 · most notably Pennsylvania v. Labron (1996), State v. Januszewski (1980)
232 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 Katz v. United States · United States v. Wade · Coolidge v. New Hampshire · Chambers v. Maroney · South Dakota v. Opperman
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 234 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a search or seizure without a warrant is deemed unreasonable for constitutional purposes. Coolidge v. New Hampshire, 403 U.S. 443, 454 , 91 S.Ct. 2022 [2031], 29 L.Ed.2d 564 (1971). The warrant requirement, however, is excused where exigent circumstances exist. Id. Exceptions arise where the need for prompt police action is imperative, either because evidence sought to be preserved is likely to be destroyed or secreted from investigation, or because the officer must protect himself from danger to his person by checking for concealed weapons.”
3 later decisions quote this exact passage · from the majority“[I]n considering the reasonableness of a given search or seizure of an automobile, the need for a warrant is often excused by exigent circumstances. The reasons are two-fold. First, a vehicle is highly mobile and the likelihood is therefore great that it and its contents may never be found if police were prohibited from immobilizing it until a warrant can be secured. Second, one’s expectation of privacy with respect to an automobile is significantly less than that relating to one’s home or office.”
2 later decisions quote this exact passage · from the majority“It is reasonable ... for constitutional purposes for police to seize and hold a car until a search warrant can be obtained, where the seizure occurs after the user or owner has been placed into custody, where the vehicle is located on public property, and where there exists probable cause to believe that evidence of the commission of crime will be obtained from the vehicle.”
2 later decisions quote this exact passage · from the concurrence
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.