Commonwealth v. Galloway’s Empirical Analysis
1990
Citation profile
22 state decisions
How this case has been cited
Cited by 22 later decisions — most recently January 2013
22 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 282 Pa. Super. 431 - Commonwealth v. Niemetz · 348 Pa. Super. 618 - Berry v. Anderson · Commonwealth v. Carsia · 242 Pa. Super. 289 - Commonwealth v. Gallagher
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]e agree that the Attorney General and his agents are empowered to apply for warrants and to make arrests in those instances where an investigation or prosecution is undertaken pursuant to [Section 205 of the Commonwealth Attorneys Act, 71 P.S.] § 732-205. Obviously, that arrest power is designed to facilitate the investigative and prosecutorial aims of the Attorney General’s office. But the power is limited thereby, and we will not read the statute to expand the scope of that power beyond the bounds of the legislative intent underlying it. The specific issue to be decided here is whether those arrest powers, invested in a "law enforcement” officer for purposes of investigating and prosecuting offenses listed in [Section 205], are also of a general nature in the same sense by which municipal police officers and the State Police are authorized by statute to arrest as “police officers”. Neither the language of the [Commonwealth Attorneys] Act itself, its legislative history, nor case law convinces us that there is any reasonable interpretation of the [Commonwealth Attorneys] Act which allows the Attorney General to arrest for offenses outside of those contemplated by the primary purpose behind the statute. The power of arrest under the [Commonwealth Attorneys] Act is limited to those actions which fall within the "scope of employment” as defined and circumscribed by the specific offenses in [Section 205]. The Attorney General is a "law enforcement officer” and not a "police o”
1 later decision quote this exact passage · from the majority“(a) Law enforcement; criminal investigations. — The Attorney General shall be the chief law enforcement officer of the Commonwealth ... The Attorney General shall have the power to investigate any criminal offense which he has the power to prosecute under section 205; he shall continue the existing programs relating to drug law enforcement. The Pennsylvania State Police shall cooperate with the Attorney General and furnish such services as the Attorney General shall request.”
1 later decision quote this exact passage · from the majority“(c) Certain arrests authorized — In addition to any other powers of arrest, a police officer is hereby authorized to arrest without a warrant any person who the officer has probable cause to believe has violated the provisions of this section, regardless of whether the alleged violation was committed in the presence of such officer.”
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.