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← 53 OHIOST2D 204 - State v. Kessler

State v. Kessler’s Empirical Analysis

1978

Citation profile

251
cited by 251 later decisions
1
states following
March 2026
most recently cited

251 state decisions

How this case has been cited

Cited by 251 later decisions — most recently March 2026 · most notably State v. Bobo (1988), City of Xenia v. Wallace (1988)

251 state decisions

1010197819801990200020102020decided

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 Chapman v. State of California · Katz v. United States · Carroll v. United States · Coolidge v. New Hampshire · Chambers v. Maroney

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

  1. “a belief reasonably arising out of circumstances known to the seizing officer, that an automobile or other vehicle contains that which by law is subject to seizure and destruction.”
    7 later decisions quote this exact passage
  2. “per se unreasonable — subject only to a few specifically established and well-delineated exceptions.”
    5 later decisions quote this exact passage
  3. “Furtive movements alone are not sufficient to justify the search of an automobile without a warrant. However, where a furtive movement has been made by occupants of a vehicle in response to the approach of police officers, the addition of other factors may give rise to a finding of probable cause to search the vehicle.”
    1 later decision quote this exact passage

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.