United States v. Silvestri’s Empirical Analysis
787 F.2d 736 · 1986
Citation profile
46 federal appellate · 26 district · 28 state decisions
How this case has been cited
Cited by 112 later decisions (1 by the Supreme Court) — most recently August 2025 · most notably Murray v. United States (1988), United States v. Zapata (1994)
46 federal appellate · 26 district · 28 state decisions — followed in 18 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
Relies on Franks v. Delaware · Nix v. Williams · Segura v. United States · Sea-Land Service, Inc. v. Federal Maritime Commission · United States v. Satterfield
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 112 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[alb-sent some overriding considerations . . ., the doctrine requires that the fact or likelihood that makes the discovery inevitable arise from circumstances other than those disclosed by the illegal search itself'); United States v. Silvestri, 787 F.2d 736, 744 (1st Cir. 1986) ("[T]here are three basic concerns which surface in an inevitable discovery analysis: are the legal means truly independent; are both the use of the legal means and the discovery by that means truly inevitable; and does the application of the inevitable discovery exception either provide an incentive for police misconduct or significantly weaken fourth amendment protection?”
7 later decisions quote this exact passage · from the dissent“In the classic independent source situation, information which is received through an illegal source is considered to be cleanly obtained when it [also] arrives through an independent source.”
4 later decisions quote this exact passage · from the majority“admission of evidence that has been discovered by means wholly independent of any constitutional violation.”
2 later decisions quote this exact passage · from the majority
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.