United States v. Watts’s Empirical Analysis
67 F.3d 790 · 1995
Citation profile
40 federal appellate · 4 district · 8 state decisions
How this case has been cited
Cited by 75 later decisions (1 by the Supreme Court) — most recently March 2022 · most notably United States v. Watts (1997), State v. Cowans (1999)
40 federal appellate · 4 district · 8 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.
Appellate journey
Relationships
Applies 18 U.S.C. § 924 · 21 U.S.C. § 841 (§ 401 of the Controlled Substances Act)
Relies on Missouri v. Continential Insurance Cos. · Griffin v. Wisconsin · Johnson v. Righetti · North Star Steel Co. v. Thomas · Domby 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 75 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A probation officer acts as a stalking horse if he conducts a probation search on prior request of and in concert with law enforcement officers. However, collaboration between a probation officer and police does not in itself render a probation search unlawful. The appropriate inquiry is whether the probation officer used the probation search to help police evade the Fourth Amendment’s usual warrant and probable cause requirements or whether the probation officer enlisted the police to assist his own legitimate objectives. A probation officer does not act as a stalking horse if he initiates the search in the performance of his duties as a probation officer.”
3 later decisions quote this exact passage · from the majority“[t]here is some tension among our cases regarding whether a probation search must be supported by probable cause to believe that the probationer resides on the premises or whether a 'reasonable' belief will suffice.”
3 later decisions quote this exact passage · from the majority“this would be a different case if police officers had targeted a suspect as part of a normal law enforcement investigation and then enlisted the help of a probation officer in order to search the suspect's home without a warrant.”
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.