New York v. Harris’s Empirical Analysis
1990
Citation profile
235 federal appellate · 56 district · 525 state decisions
How this case has been cited
Cited by 1,048 later decisions (12 by the Supreme Court) — most recently February 2024 · most notably Minnesota v. Olson (1990), Hudson v. Michigan (2006)
235 federal appellate · 56 district · 525 state decisions — followed in 41 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 · Wong Sun v. United States · United States v. Leon · Payton v. New York · Edwards v. Arizona
Cited together with Payton v. New York · Wong Sun v. United States · Brown v. Illinois · Miranda v. State of Arizona Vignera · Terry v. Ohio
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 1,048 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'the challenged evidence ... is unquestionably the product of the illegal governmental activity- i.e., the wrongful detention.'”
36 later decisions quote this exact passage · from the majority“[T]he rule in Payton was designed to protect the physical integrity of the home; it was not intended to grant criminal suspects ... protection where the police have probable cause to arrest the suspect for committing a crime.... Nothing in the reasoning of that case suggests that an arrest in a home without a warrant but with probable cause somehow renders unlawful continued custody of the suspect once he is removed from the house. There could be no valid claim here that ... [the defendant] was immune from prosecution because his person was the fruit of an illegal arrest.... Nor is there any claim that the warrantless arrest required the police to release ... [the defendant] or that ... [the defendant] could not be immediately rearrested if momentarily released.... For Fourth Amendment purposes, the legal issue is the same as it would be had the police arrested ... [the defendant] on his doorstep, illegally entered his home to search for evidence, and later interrogated ... [the defendant] at the station house.”
14 later decisions quote this exact passage · from the majority“where the police have probable cause to arrest a suspect, the exclusionary rule does not bar the State's use of a statement made by the defendant outside of his home, even though the statement is taken after an arrest made in the home in violation of Payton.”
13 later decisions quote this exact passagee.g. Maulden v. State · Edwards v. State
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.