53 Va. App. 1 - Whitehead v. Commonwealth’s Empirical Analysis

Citation profile

2 state decisions

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

1. “In this case, the officers had probable cause to search the car following Xanto's alert. And, by the time the officers searched Whitehead, they had probable cause to search his person through the process of elimination. Each fruitless search—of the car and of the other occupants of the car—increased the likelihood that Whitehead possessed the odorous contraband detected by Xanto's trained nose. While it may have been more a result of luck rather than a profound understanding of the Fourth Amendment, we hold that by the time the officers searched Whitehead they possessed the necessary probable cause to justify the search.”

   1 later decision quote this exact passage
   e.g. Whitehead v. Com.

2. “[e]ven if we assume arguendo that a trained dog's detection of the scent of drugs coming from an occupied car does not, of itself, provide sufficiently particularized probable cause to search each of the car's occupants for drugs, ... on these facts ... the search of Whitehead's person did not violate the Fourth Amendment.”

   1 later decision quote this exact passage
   e.g. Whitehead v. Com.

3. “assess[es] the existence of probable cause at the time the search [is] conducted.”

   1 later decision quote this exact passage · from the concurrence
   e.g. Whitehead v. Com.