Sprosty v. Buchler’s Empirical Analysis
79 F.3d 635 · 1996
Citation profile
38 federal appellate · 4 district · 17 state decisions
How this case has been cited
Cited by 89 later decisions — most recently August 2025 · most notably Lambert v. Blodgett (2004), United States v. Brooks (1997)
38 federal appellate · 4 district · 17 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 Miranda v. State of Arizona Vignera · Schneckloth v. Bustamonte · Edwards v. Arizona · Townsend v. Sain · Singleton v. Wulff
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 89 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[C]ourts have identified the following factors to be significant in determining whether a person is in custody: whether and to what extent the person has been made aware that he is free to refrain from answering questions; whether there has been prolonged coercive, and accusatory questioning, or whether police have employed subterfuge in order to induce self-incrimination; the degree of police control over the environment in which the interrogation takes place, and in particular whether the suspect’s freedom of movement is physically restrained or otherwise significantly curtailed; and whether the suspect could reasonably believe that he has the right to interrupt prolonged questioning by leaving the scene.”
2 later decisions quote this exact passage · from the majority“formal arrest or restraint on freedom of movement of the degree associated with a formal arrest.”
2 later decisions quote this exact passage · from the majority“As the district judge also noted, to hold that by Mirandizing a suspect the police may create a custodial setting where one would not otherwise exist would result in discouraging the desirable practice of giving Miranda warnings at the earliest point where a police-citizen encounter progresses beyond an investigatory stop. Cf. Berkemer, 468 U.S. at 430-32, 437-40, 104 S.Ct. at 3145-46, 3148-50 (bright-line rule that Miranda warnings be given as soon as suspect is in custody). Yet in the context of a prolonged detention where there is persistent, accusatory questioning by several officers, the fact that the police observed certain formalities of a custodial arrest without actually telling Sprosty that he was not under arrest does provide some support for an inference that Sprosty was in custody for purposes of Miranda .”
1 later decision 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.