Reed v. State’s Empirical Analysis

Citation profile

19 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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[d]iscovei-y of an outstanding wari-ant during an illegal detention of an individual breaks the connection between the discovered evidence and the primary taint ... [T]he independent probable cause evidenced by the valid arrest warrants demonstrates that the evidence found during the search of appellant’s person was not discovei'ed through exploitation of the initial illegal arrest.”

   3 later decisions quote this exact passage
   e.g. 165 Md. App. 502 - Myers v. State · Fletcher v. State

2. “To hold otherwise would place us on the horns of a dilemma. We would have to say that the police should have released a suspect who was in their custody illegally notwithstanding the existence of warrants for that suspect’s arrest, or, alternatively, that the fruits of a search incident to a legal arrest are inadmissible because the arrest would not have occurred “but for” an illegal detention. Both possibilities have serious implications and entail line drawing that we are not prepared to do. For example, if the police illegally detain a suspect and discover arrest warrants, may they release the suspect and re-arrest him and then conduct a legal search? If not, is he forever immune from the consequences of a search incident to a subsequent arrest under those same warrants? If so, when can they re-arrest him? After he steps outside the door of the police station? A block away? The same day? And so forth.”

   1 later decision quote this exact passage · from the dissent
   e.g. Fletcher v. State

3. “[WJhether, when during the course of an illegal detention of appellant for the stated purpose of determining appellant’s identity, a valid warrant for the arrest of appellant was discovered upon establishing appellant’s identity and appellant was arrested under authority of that warrant, contraband found during the subsequent book-in inventory search is admissible into evidence against appellant because the existence of the warrant sufficiently attenuates the connection between the illegal detention and the discovery of the contraband. 38”

   1 later decision quote this exact passage
   e.g. State of Texas v. Mazuca, Alvaro