United States v. Watson’s Empirical Analysis
950 F.2d 505 · 1991
Citation profile
10 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 23 later decisions — most recently April 2023
10 federal appellate · 3 district · 1 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 31 U.S.C. § 5324 (§ 1354 of the Money Laundering Control Act of 1986)
Relies on Wong Sun v. United States · Rakas v. Illinois · Nardone v. United States · Cherek v. United States · Yi Au Lau v. United States Immigration & Naturalization Service
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A mere causal connection between information gained during an illegal search and evidence prepared for trial does not require automatic exclusion of the evidence. “[S]uch connection may have become so attenuated as to dissipate the taint.” Nardone v. United States, 308 U.S. 338, 341 , 60 S.Ct. 266, 268 , 84 L.Ed. 307 (1939). Moreover, in determining whether exclusion is proper, the court does not simply inquire whether the evidence would have been discovered “but for” the illegal conduct. “Rather, the more apt question in such a case is ‘whether, granting establishment of the primary illegality, the evidence to which instant objection is made has been come at by exploitation of that illegality or instead by means sufficiently distinguishable to be purged of the primary taint.’” Wong Sun v. United States, 371 U.S. 471, 487-88 , 83 S.Ct. 407, 417-18 , 9 L.Ed.2d 441 (1963) (quoting Maguire, Evidence of Guilt 221 (1959)).”
3 later decisions quote this exact passage · from the majority“[W]here a law enforcement officer merely recommends investigation of a particular individual based on suspicions arising serendipitously from an illegal search, the causal connection is sufficiently attenuated so as to purge the later investigation of any taint from the original illegality.”
3 later decisions quote this exact passage · from the majority“The. mere fact that information gained during an illegal search gives rise to a subsequent, separate investigation ... does not necessarily taint the later investigation.”
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.