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← 98 Haw. 337 - State v. Barros

State v. Barros’s Empirical Analysis

2002

Citation profile

8
cited by 8 later decisions
1
states following
May 2023
most recently cited

8 state decisions

How this case has been cited

Cited by 8 later decisions — most recently May 2023

8 state decisions

50200220102020decided

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 Michigan v. Summers · Atwater v. City of Lago Vista · Wyoming v. Sandra Houghton · Curtiss-Wright Corp. v. Schoonejongen · State v. Kaluna

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

  1. “In order to pass constitutional muster, the length of time [the officer] could permissibly detain [the defendant] must have been “no greater in intensity than absolutely necessary under the circumstances.” [State v.] Kaluna, 55 Haw. [361,] 369, 520 P.2d [51,] 58-59 [(1974)]. The warrant check was completed entirely within the time required for [the officer] to issue the citation. The evidence in the record also demonstrates that [the officer] neither used the stop as a pretext to allow him to request the warrant check, nor did he prolong impermissibly the stop in order to allow dispatch to complete the warrant check he requested. Moreover, there is no indication that [the officer] requested any information other than what was necessary to facilitate the warrant check. Thus, [the officer’s detention of [the defendant] to run the warrant check did not constitute an unreasonable intrusion.”
    2 later decisions quote this exact passage · from the majority
  2. “no greater in intensity than absolutely necessary under the circumstances.”
    2 later decisions quote this exact passage · from the majority
  3. “approached [the defendant], intending to issue ... a citation for jaywalking. [The officer] forgot his citation book in his patrol car, and decided not to retrieve it. [The officer] identified himself to [the defendant], explained the reason for the stop, and informed [the defendant] that he was going to cite [him] for jaywalking. In response to [the officer’s] request for identification, [the defendant] presented his State of Hawai'i Identification Card. [The officer] used his shoulder-mounted police radio to request a warrant check. He requested a warrant check because “this was a high drug activity area.” [The officer] also stated that [the defendant] was “acting funny” because “he started shifting from one foot to the other ... trying to circle me.” [The officer] interpreted his conduct as leading to a possible attack or that [the defendant] “just didn’t wanna be there.” In addition, [the officer] generally requests warrant cheeks to determine “if the person has any unfinished business with the court.” At that time, [the officer] began to write down the salient information to issue a citation. Because he did not have his citation book with him, [the officer] recorded the necessary information in his notebook. Within a couple of minutes, dispatch confirmed that [the defendant] had outstanding warrants. [The officer] placed [the defendant] under arrest for contempt of court.”
    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.