Commonwealth v. Shaffer’s Empirical Analysis
1998
Citation profile
4 state decisions
How this case has been cited
Cited by 4 later decisions — most recently July 2015
4 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 Pennoyer v. Neff · Commonwealth v. Stair · Commonwealth v. England · Commonwealth v. Price · Commonwealth v. Labron
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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[i]f an arrest is made in this State by an officer of another state in accordance with § 1932 of this title, the officer shall without necessary delay take the person arrested before a justice of the peace of the county in which the arrest was made, who shall conduct a hearing for the purpose of determining the lawfulness of the arrest.” Id. (citing Del.Code., tit. 11, § 1933). 6 . In a footnote, our Supreme Court noted that this Court’s decision in Shaffer”
3 later decisions quote this exact passage“In our opinion, the present case turns upon concepts of jurisdiction and sovereignty. There seems to be no question that Pennsylvania police officers are without inherent jurisdiction to make an arrest in New York State. Thus, the jurisdiction or authority of [the Pennsylvania trooper] to make an arrest in New York State, if any, is gained only through the grace of New York State. That grace, in this instance, is found in the New York version of the reciprocal or uniform Act on close pursuit. There also seems to be no dispute that the New York Close Pursuit Act was violated. Under the terms of the Act, an individual arrested in New York by an out-of-state-police [sic] officer after being closely pursued into New York must be taken before a local criminal court which shall conduct a hearing to determine if the arrest was in compliance with the Act. Since [the Pennsylvania trooper] did not take [Shaffer] in front of a local criminal court to determine if the arrest complied with the Act, the arrest violated New York’s Close Pursuit Act and was therefore unlawful. The more significant question is what is the appropriate remedy for [Shaffer’s] “unlawful” arrest.”
2 later decisions quote this exact passage“Since the Commonwealth is putting forth this argument it is not surprising that New York courts have at least twice refused to suppress evidence where close pursuit statutes were seemingly violated. We cannot agree. Although it is quite proper to defer to New York law to determine whether or not the New York Statute [sic] had been complied with, there is no reason to refer or defer to New York law to determine policy matters relating to proper remedy for an unlawful arrest of a Pennsylvania resident by a Pennsylvania police officer for crimes committed in Pennsylvania. It is really a matter of sovereignty. Pennsylvania courts and Pennsylvania law must govern the rights of a Pennsylvania resident arrested by Pennsylvania police officers for crimes committed in Pennsylvania, even if the arrest is effectuated in New York State, not New York courts or New York law.... As a matter of accountability, sovereignty and simplicity, it is for Pennsylvania to dictate how its police officers are to carry out their duties and the consequences for violating such dictates. The remedy for an illegal arrest in Pennsylvania is suppression of the fruits of the illegal arrest.”
1 later decision quote this exact passage
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.