Commonwealth v. Shiflet’s Empirical Analysis
1995
Citation profile
36 state decisions
How this case has been cited
Cited by 36 later decisions — most recently April 2017 · most notably 2002 Pa. Super. 383 - Commonwealth v. Reppert (2002), Commonwealth v. Millner (2005)
36 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 Terry v. Ohio · Katz v. United States · Chimel v. California · Coolidge v. New Hampshire · New York v. Belton
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]ll companions of [an] arrestee within the immediate vicinity, capable of accomplishing a harmful assault on the officer, are constitutionally subjected to the cursory `pat-down' reasonably necessary to give assurance that they are unarmed.”
2 later decisions quote this exact passage · from the majority“In Gary, supra, the Pennsylvania Supreme Court switched course from its earlier mid-1990’s cases that provided greater protections to citizens of Pennsylvania in their automobiles. It aligned Pennsylvania jurisprudence with the United States Supreme Court’s interpretation of the Fourth Amendment with regard to vehicle searches. In Gary , Philadelphia police observed a vehicle with tinted windows that they believed violated the Motor Vehicle Code. After stopping the automobile, the police detected the smell of marijuana emanating from the vehicle. Gary told police that there was marijuana in the car and police summoned a canine unit to conduct a sniff of the vehicle. Gary, who had been placed in the back of a police cruiser, then attempted to flee but was captured. Police found two pounds of marijuana under the front hood of the car. Gary unsuccessfully litigated a suppression motion and was found guilty of possession with intent to deliver marijuana. This Court reversed and remanded for a new trial, concluding that, because Gary was in custody at the time of the search of the automobile, no exigent circumstances existed for the search. The Pennsylvania Supreme Court reversed this Court, finding that the only exigent circumstance required of an automobile is its ’mobility. Thus, it held that, where police possess probable cause to search a car, a warrantless search is permissible.”
1 later decision quote this exact passage · from the majority“Here, Appellee was not subject to a formal arrest before her purse was seized, and she was standing outside of the vehicle with her purse when the search and seizure took place. The Commonwealth does not present any facts that would indicate that Appellee was subject to a custodial arrest, and it is conceded that the police had neither probable cause nor a reasonable suspicion that Appellee was engaged in any illegal activity.... It was only in connection with Trooper Taylor's offer to drive Appellee home that the apparent need on the part of Trooper Taylor to search Appellee's purse arose. Trooper Taylor did not indicate that he needed to search Appellee's purse incident to the arrest of the driver and the other passenger, and had no reason to believe that Appellee was armed or was engaged in criminal conduct. Thus, the facts do not warrant an expansion of the search incident to arrest exception to this bystander.”
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.