Pistro v. State’s Empirical Analysis
1979
Citation profile
32 state decisions
How this case has been cited
Cited by 32 later decisions — most recently March 2024 · most notably State v. Lee (1981), 377 Pa. Super. 117 - Commonwealth v. Carelli (1988)
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 Brinegar v. United States · 9 Cal. 3d 626 - Lorenzana v. Superior Court · 71 Cal. 2d 84 - People v. Berutko · Gorman v. United States · Erickson v. State
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Police officers walking through an unfenced driveway to inquire at premises have been held not to invade any reasonable expectation of privacy. The driveway was a normal means of ingress and egress impliedly open to public use by one desiring to speak to occupants of the garage, or to park off the street while visiting occupants of the house. This is not a case of an officer leaving such a means of public access to spy from an area not impliedly open to the public. There was no invasion of rights to privacy, and [the trooper] could constitutionally observe what was in plain view in the garage.”
2 later decisions quote this exact passage“Thus, it [was] held that an officer who [left the] driveway [of a residence] and crosse[d] a portion of a yard which was not a normal access route to any door, so as to position himself next to a window in order to spy through a gap of about two inches at the bottom of a window shade, unlawfully intruded on the rights of privacy of the occupants. In contrast, a [court upheld a search involving] a police officer's observations through a screen door, ... [when the officer used] a normal means of access to the house leading up to a side door. Similarly, observations from a common passageway between apartments have been upheld. [And] officers walking through an unfenced driveway to inquire at premises have been held not to invade any reasonable expectation of privacy.”
1 later decision quote this exact passagee.g. Martin v. State“A private person or a peace officer without a warrant may arrest a person (1) for a crime committed or attempted in his presence; (2) when the person has committed a felony, although not in his presence; (3) when a felony has in fact been committed, and he has reasonable cause for believing the person to have committed it.”
1 later decision quote this exact passagee.g. Sumdum v. State
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.