91 Wash. App. 554 - State v. McKenna’s Empirical Analysis
1998
Citation profile
51 state decisions
How this case has been cited
Cited by 51 later decisions — most recently February 2021 · most notably State v. O'NEILL (2003), 148 Wash. 2d 564 - State v. O'Neill (2003)
51 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 Terry v. Ohio · Schneckloth v. Bustamonte · Chimel v. California · Schmerber v. State of California · Johnson v. United States
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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The officer must have probable cause to arrest before commencing the search, which is also to say that the arrest cannot be justified by the fruits of the search.”
2 later decisions quote this exact passagee.g. State v. Neeley · State v. O'NEILL“[N]othing herein means that a trial court must suppress evidence when an officer (a) arrests a defendant with probable cause to make a custodial arrest; (b) conducts a search contemporaneous with the arrest; but (c) for objectively manifested reasons arising after the search (e.g., being called to another, more pressing emergency), does not actually take the defendant into custody. We have no occasion to consider such a situation in deciding this case.”
1 later decision quote this exact passagee.g. State v. Balch“An otherwise lawful custodial arrest will support a search incident to it, provided that the evidence does not show an unconditional decision to release prior to the officer's making the search.”
1 later decision quote this exact passagee.g. State v. O'NEILL
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.