Angulo v. State’s Empirical Analysis
1987
Citation profile
34 state decisions
How this case has been cited
Cited by 35 later decisions — most recently October 2017 · most notably Webb v. State (1988), Eisenhauer v. State (1988)
34 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 Illinois v. Gates · Aguilar v. Texas · Spinelli v. United States · Jones v. United States · Draper 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he “totality of the circumstances” approach in determining probable cause ... applies to warrantless as well as warrant searches.... [T]he duty of the reviewing court is to look to the “totality of the circumstances” to determine if there exists a substantial basis for concluding that probable cause existed at the time of the questioned action. [[Image here]] Appellant argues that his behavior in the instant case is consistent with innocent activity.... [T]he relevant inquiry is not whether particular conduct is “innocent” or “guilty,” but the degree of suspicion that attaches to particular types of non-criminal acts.... [S]eemingly innocent behavior becomes suspicious in light of the anonymous tip. [The tip is even stronger when it comes from a cooperating individual who is known to the officers.] [[Image here]] In conclusion, the concept of probable cause is a fluid one. It deals in probabilities, not certainties.”
2 later decisions quote this exact passagee.g. Carr v. State · Rance v. State“The record reflects that Officer F.L. Shafer received an anonymous telephone tip on June 23, 1983, which revealed the following information: Shafer was instructed that a red American Motors Pa cer automobile license plate identification RUY 662 contained narcotics; the informant told Shafer that the automobile would contain two Cuban males, one of whom would be appellant. In addition, the informant explained that the Pacer’s gasoline cap was missing and that a red rag was being used in its place. The destination of the automobile would be 7201 Spencer Highway, Casa Maria Apartments, No 54. The informant also told Shafer that time was of the essence as the car was already enroute. The informant did not reveal the source of his information. After reviewing this information from Shafer, Lieutenant William McBeth drove to the Casa Maria Apartments and observed the above-mentioned automobile occupied by two males parked in a space directly in front of Apt. No. 54. McBeth also noted the red rag hanging from the gasoline intake. McBeth observed the two men get out of the car as they were approached by others. When an additional automobile drove into the lot and parked directly behind the Pacer, McBeth, based on his experience in narcotics investigation, initiated an investigatory stop and ascertained that one of the original occupants of the automobile was appellant, the party named by the informant. When Shafer arrived on the scene he talked briefly with appellant and then searched”
1 later decision quote this exact passagee.g. Campbell v. State“The independent police corroboration in the instant case was surely not any less extensive than in Gates, supra, simply because the officers had less time. The amount of time the officers have for investigation does not control the issue of probable cause, but rather, the amount of effective cooperation the officers make in the time allowed. In the instant case the independent investigation of the police confirmed aspect of the informant’s tip save whether or not the vehicle actually contained the contraband. In the instant case the police even had reasonable belief the appellant was carrying the contraband.”
1 later decision quote this exact passagee.g. Campbell v. State
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.