State v. Eleneki’s Empirical Analysis
2000
Citation profile
12 state decisions
How this case has been cited
Cited by 12 later decisions — most recently May 2022
12 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
Applies 18 U.S.C. § 3109
Relies on State v. Okumura · Leahy v. United States · Dickey v. United States · State v. Wilson · 102 Wash. 2d 548 - State v. Myers
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[F]actual determinations made by the trial court deciding pretrial motions in a criminal case [are] governed by the clearly erroneous standard[,]”
5 later decisions quote this exact passage · from the majoritye.g. Birano v. State. · State v. Edwards“conclusions of law are reviewed under the right/wrong standard.”
2 later decisions quote this exact passage · from the majoritye.g. State v. Hosaka · State v. Riveira“In Dixon , we held that “HRS § 803-11 is not implicated where entry is gained through an open door without use of force.” 83 Hawai'i at 21 , 924 P.2d at 189 . In the present case, although the ruse prompted Foster to partially open the door, Officer Kenui had to use force to gain entry because Foster attempted to close the door after recognizing Kenui. Became force ivas used, the officers were required to comply with HRS § 80S-37 and Garcia. The circuit court did not reach the issue whether the officers complied with HRS § 803-37 and Garcia; the ICA held that the requirements were not satisfied. We disagree with the ICA. HRS § 803-37 provides that officers executing a search warrant “may enter [the place to be searched] without demanding permission if the officer finds it open. If the doors are shut the officer must declare the officer’s office and the officer’s business, and demand entrance.” Under [HRS] § 803-37 and Garcia, if the occupants do not open the door after the officers knock and announce, the officers may break the door after giving the occupants a reasonable time to respond. In the present case, the officers employed a permissible ruse, which induced Foster to open the door approximately one foot. This was sufficient to render the door “open” for purposes of the statute. Therefore, the officers were not. required to knock and announce before enteñng, and the force used by the officers to further open the door against Foster’s resistance ivas not• a breaking.”
1 later decision quote this exact passage · from the majoritye.g. State v. Harada
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.