Thomas v. State’s Empirical Analysis

Citation profile

1 federal appellate · 10 state decisions

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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““The search of an automobile is generally reasonable even if the defendant has already been removed from the automobile to be searched and is under the control of the officer. [Citations.] Where the officer initiates contact with the defendant, either by actually confronting the defendant or by signaling confrontation with the defendant, while the defendant is still in the automobile, and the officer subsequently arrests the defendant (regardless of whether the defendant has been removed from or has exited the automobile), a subsequent search of the automobile’s passenger compartment falls within the scope of Belton and will be upheld as reasonable. [Citation.] Our decisions have consistently upheld the search of the passenger compartment of an automobile when the officer initiated contact with the defendant while the defendant was still within the automobile later searched, regardless of whether the defendant was arrested while actually occupying the automobile or after having recently been removed from the automobile. [Citations.] However, where the defendant has voluntarily exited the automobile and begun walking away from the automobile before the officer has initiated contact with him, the case does not fit within Belton’s bright-line rule, and a case-by-case analysis of the reasonableness of the search under Chimel becomes necessary. [Citation.]” (Emphasis added.) Hudgins, 52 F.3d at 119 .”

   2 later decisions quote this exact passage
   e.g. State v. Gant · 203 Ill. 2d 26 - People v. Stehman

2. “[T]he arrest and subsequent search should not be invalidated merely because the defendant is outside the automobile. The occupants of a vehicle cannot avoid the consequences of Belton merely by stepping outside of the vehicle as the officers approach.”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Gant

3. “[b]ased on the record ... we are unable to ascertain whether [the officer's] safety was endangered or whether the preservation of the evidence was in jeopardy,”

   1 later decision quote this exact passage · from the majority
   e.g. Florida v. Thomas