531 So. 2d 88 - Caplan v. State’s Empirical Analysis
1988
Citation profile
2 federal appellate · 32 state decisions
How this case has been cited
Cited by 35 later decisions — most recently August 2018 · most notably Cross v. State (1990), Brown v. Com. (2005)
2 federal appellate · 32 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 Wong Sun v. United States · Coolidge v. New Hampshire · South Dakota v. Opperman · Texas v. Brown · Sedillo v. United States
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]hat the mere observation of an opaque container [such as partially burned cigarette paper], without more, cannot constitute probable cause. There must be at least an additional objective and reasonably specific element justifying the state agent's inference of wrongdoing. Under a probable cause standard, that is, the officer at the scene must be able to explain to an objective magistrate or judge "just how it is possible to distinguish such a [marijuana] cigarette from other hand-rolled cigarettes."”
3 later decisions quote this exact passage · from the concurrencee.g. State v. Cross · M.L. v. State“Even if we assume this officer had special expertise to recognize illegal narcotics, this case more closely resembles the line of authority holding that the mere observance of an opaque container commonly used to transport contraband does not, without more, give rise to probable cause to search.”
2 later decisions quote this exact passage · from the concurrence“[T]here is no need to perform the caretaking function of an inventory when the vehicle is not in the care, custody, and control of the police.”
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.