75 Wash. App. 460 - State v. Chapin’s Empirical Analysis
1994
Citation profile
38 state decisions
How this case has been cited
Cited by 38 later decisions — most recently March 2022 · most notably State v. Ladson (1999), 138 Wash. 2d 343 - State v. Ladson (1999)
38 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 Wong Sun v. United States · Scott v. United States · United States v. Lefkowitz · Kashif v. United States · United States v. Ceccolini
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We decline to follow a pure objective approach [the “could” test] for two reasons. First, if a court’s inquiry is limited to determining whether the police had a lawful basis for making the stop which lead [sic] to the search and/or seizure, logically there can no longer be a pretext rule. This is because, under a pure objective approach, an officer’s actions are per se reasonable if they are pursuant to lawful authority. The entire purpose of the pretext rule is to deter police from using their lawful authority to detain a person for a minor olfense in order to investigate or search for evidence of a more serious offense .... We reject this approach because it extinguishes the rule. Second, under a pure objective approach, there is no basis for judicial review of an officer’s use of the discretionary power to stop so long as the stop has a lawful basis.”
1 later decision quote this exact passagee.g. Alejandre v. State“We do not, by adopting the objective approach, intend to turn suppression hearings into a lengthy debate over the normal practices and procedures of the police agency in question. Normally, the testimony of the officer involved in the stop should suffice to establish what those practices and procedures are.”
1 later decision quote this exact passage · from the dissent“[T]he fact that the officer does not have the state of mind which is hypothecated by the reasons which provide the legal justification for the officer’s action does not invalidate the action taken as long as the circumstances, viewed objectively, justify that action.”
1 later decision quote this exact passage · from the dissent
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.