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← 64 Haw. 130 - State v. Kapoi

State v. Kapoi’s Empirical Analysis

1981

Citation profile

34
cited by 34 later decisions
1
states following
June 2021
most recently cited

2 district · 32 state decisions

How this case has been cited

Cited by 34 later decisions — most recently June 2021 · most notably State v. Wyatt (1984), State v. Wallace (1996)

2 district · 32 state decisions

16019811990200020102020decided

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 · Katz v. United States · Carroll v. United States · Coolidge v. New Hampshire · Chambers v. Maroney

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

  1. “even the 'open view' of possible contraband, without more, furnished no basis for its seizure without a warrant. For 'no amount of probable cause can justify a warrantless search or seizure absent exigent circumstances.'”
    2 later decisions quote this exact passage · from the majority
  2. “The open view doctrine is distinguishable from the visually similar, but legally distinct, plain view doctrine. In the plain view situation[,] the view takes place after an intrusion into activities or areas as to which there is a reasonable expectation of privacy. The officer has already intruded, and, if his [or her] intrusion is justified, the objects in plain view, sighted inadvertently, will be admissible. In the open view situation, however, the observation takes place from a non-intra-sive vantage point. The governmental agent is either on the outside looking outside or on the outside looking inside [at] that which is knowingly exposed to the public. The object under observation is not within the scope of the constitution.”
    1 later decision quote this exact passage · from the majority
  3. “The car was exposed to public view; there was a foreseeable risk that the evidence it sheltered might be removed before a warrant could be sought some hours later. Moreover, the object in question was a firearm likely to draw the attention of possible intruders in a neighborhood considered a “trouble spot” by the police. ... [T]he threat to public safety engendered by the situation also causes us to consider the officer’s actions reasonable.”
    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.