State v. Ortiz’s Empirical Analysis
1984
Citation profile
3 federal appellate · 1 district · 52 state decisions
How this case has been cited
Cited by 56 later decisions — most recently August 2020 · most notably 6 Va. App. 507 - Servis v. Commonwealth (1988), United States v. Williams (1987)
3 federal appellate · 1 district · 52 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 · Adams v. Williams · Sibron v. State of New York Peters · New York v. Belton · United States v. Place
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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although the trial and intermediate courts thought Bennett had probable cause to arrest Ortiz the instant he suspected he felt a gun butt, we are not so certain. Bennett could not be positive the knapsack contained a gun until he opened it. Indeed, Ortiz's counsel argued this point at the suppression hearings. Furthermore, it is not illegal in Hawaii [Hawai'i] to carry a concealed gun if the carrier has a license. See, HRS § 134-9 (Supp.1983). Thus, prior to opening the knapsack it is likely Bennett had grounds for a reasonable inference that Ortiz was armed rather than probable cause to believe Ortiz was committing a crime.”
1 later decision quote this exact passage · from the majoritye.g. State v. Tagaolo“It would defeat the purpose of a protective pat-down search to require a police officer, who seizes a closed container during a pat-down search on the reasonable suspicion that it contained a weapon, to return the container unexamined simply because it is neither a weapon nor evidence of a crime. “Police officers need not risk a shot in the back by returning containers which they reasonably suspect contain a dangerous weapon but may lack probable cause to seize.””
1 later decision quote this exact passage · from the majority“The well-established rule in this jurisdiction is that warrantless searches are presumptively unreasonable unless they fall within one of the carefully defined exceptions.”
1 later decision quote this exact passage · from the majoritye.g. State v. Rosa.
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.