State v. Beam’s Empirical Analysis
1988
Citation profile
5 state decisions
How this case has been cited
Cited by 5 later decisions — most recently March 2019
5 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 Illinois v. Gates · Michel v. United States · SGRO v. United States · Dumbra v. United States · State v. Vestal
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Information from a reliable informant showing the defendant possessed one pound of marijuana approximately a week earlier at her home and information from another informant that de fendant was selling marijuana at an unspecified location the day the warrant was issued, does not supply a magistrate with a substantial basis for determining there was a fair probability that contraband would be found in defendant’s home. There is nothing in the affidavit to support a finding of an ongoing activity of drug selling at defendant’s residence. Cf. State v. King, 44 N.C. App. 31 , 259 S.E. 2d 919 (1979) (large number of persons coming and going from defendant’s house corroborated other information concerning ongoing activity); State v. Arrington, supra (one informant gave information of growing marijuana plants, corroborated by information of a steady flow of traffic by people known to use drugs to and from the premises to be searched is evidence of ongoing activity).”
1 later decision quote this exact passagee.g. State v. Beam“[T]he information contained in this application is based upon my personal knowledge and upon factual information I have received from others. A reliable informant who has provided accurate and reliable information in the past and whose information in the past has led to arrest and convictions under the N.C. Controlled Substance Act has told the undersigned [Detective Hollifield] that appx. one week ago the informant saw Lilly Ann Beam with appx. 1 pound of marijuana at her home on Ridge Road. Another informant told the undersigned [Detective Hollifield] that Lilly Ann Beam sold marijuana to them on 02/07/87. Lilly Ann Beam is on probation for violation of Controlled Substance Act.”
1 later decision quote this exact passagee.g. State v. Beam“[A]s a Matter of Law . . . considering the totality of the circumstances, the issuing magistrate, had no substantial basis, based upon the information sworn to before him by Deputy Hollifield set out in the affidavit, for concluding that probable cause existed for issuance of the search warrant to search Defendant’s residence.”
1 later decision quote this exact passagee.g. State v. Beam
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.