State v. Bell’s Empirical Analysis
1990
Citation profile
64 state decisions
How this case has been cited
Cited by 64 later decisions — most recently September 2018 · most notably 922 So. 2d 517 - State v. Pigford (2006), Rivas v. United States (2001)
64 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 425 So. 2d 1222 - State v. Trahan · 319 So. 2d 396 - State v. Cann · 369 So. 2d 1345 - State v. Walker · 555 So. 2d 633 - State v. Davis · 561 So. 2d 108 - State v. Davis
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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“According to the testimony of the arresting officers, the state had no evidence that Bell exercised any control over Davis' car, that he had any other drugs in his possession on his person, that he appeared under the influence of narcotics, or that he had possession of any drug paraphernalia. It was Davis who lived in the neighborhood two doors away and who responded to the request of the police by turning down the radio. From Bell's mere presence in the car close to the sealed package on the console between the two men, a rational factfinder could not have concluded that, even assuming he was aware of the contents, Bell exercised control and dominion over the package, or that he willfully and knowingly shared with Davis the right to control it. The state's evidence was therefore insufficient to prove that Bell was in constructive possession of the cocaine, or that he had performed any act tending directly toward accomplishing that goal. R.S. 14:27; 40:967.”
6 later decisions quote this exact passage · from the majoritye.g. State v. Clay · State v. Toups“a distinctively wrapped package containing a white powder among cassette taped on a plastic console placed over the transmission hump of the car.”
3 later decisions quote this exact passage · from the majoritye.g. State v. Clay · State v. Odle“[t]he mere presence of someone in the area where the controlled dangerous substance is found, or mere association with the person found to be in possession of the contraband, is insufficient to constitute constructive possession.”
2 later decisions 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.