United States v. Lyons’s Empirical Analysis
706 F.2d 321 · 1983
Citation profile
64 federal appellate · 8 district · 32 state decisions
How this case has been cited
Cited by 127 later decisions — most recently August 2018 · most notably 102 Wash. 2d 733 - State v. Williams (1984), United States v. Whitehead (1988)
64 federal appellate · 8 district · 32 state decisions — followed in 19 states
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
Applies 18 U.S.C. § 2 · 18 U.S.C. § 924 · 21 U.S.C. § 841 (§ 401 of the Controlled Substances Act) · 28 U.S.C. § 294
Relies on Terry v. Ohio · Katz v. United States · Chimel v. California · Coolidge v. New Hampshire · Rakas v. Illinois
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 127 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[c]ustodial arrests are often dangerous; the police must act decisively and cannot be expected to make punctilious judgments regarding what is within and what is just beyond the arrestee's grasp.”
7 later decisions quote this exact passage · from the concurrence“conceivably accessible to the arrestee-assuming that he was neither `an acrobat [nor] a Houdini.'”
3 later decisions quote this exact passage · from the concurrence“No less than three different views are to be found in the cases. One is that the motel or hotel arrest is to be treated exactly like the at-home arrest, so that the officers have “no greater right to remove or search defendant’s personal belongings that were not on his person or within his immediate control than they would have if they had made the arrest in his house.” At the other extreme, it has been held that removal of the defendant’s effects from his motel room is proper, at least when the defendant does not “offer any objection or suggest any other arrangement for the safekeeping of [his] possessions,” because the hotel or motel management cannot be expected “to permit those belongings to remain indefinitely in the vacated room.” The middle ground is that since the law does not “place any responsibility on the [police] for the care of defendant’s property located in the motel room” and adequately protects the innkeeper “by statutory provisions limiting the liability of an innkeeper for loss of guests’ property,” it is only the defendant’s interests which are at stake, meaning the police are obligated to give him “the choice of leaving his belongings in the motel room or requesting the [police] to take them into custody for him.””
1 later decision quote this exact passage · from the concurrence
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.