Elliott III’s Empirical Analysis
Citation profile
8 district · 9 state decisions
How this case has been cited
Cited by 87 later decisions — most recently June 2025 · most notably Okwa v. Harper (2000), Richardson v. McGriff (2000)
8 district · 9 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 Graham v. Connor · Tennessee v. Garner · Johnson v. Jones · Behrens v. Pelletier · Slattery v. Rizzo
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 87 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“No citizen can fairly expect to draw a gun on police without risking tragic consequences. And no court can expect any human being to remain passive in the face of an active threat on his or her life. As Greenidge and Slattery illustrate, the Fourth Amendment does not require omniscience. Before employing deadly force, police must have sound reason to believe that the suspect poses a serious threat to their safety or the safety of others. Officers need not be absolutely sure, however, of the nature of the threat or the suspect’s intent to cause them harm — the Constitution does not require that certitude precede the act of self-protection.”
6 later decisions quote this exact passage“police officers are often forced to make split-second judgments — in circumstances that are tense, uncertain, and rapidly evolving.”
3 later decisions quote this exact passage“not suggest the officers shot mindlessly as much as it indicates that they sought to ensure the elimination of a deadly threat.”
2 later decisions quote this exact passagee.g. Dorothy C. Elliott, Individually and as Co-Personal Representative of the Estate of Archie Elliott, III Archie Elliott, Jr., Individually and as Co-Personal Representative of the Estate of Archie Elliott, III v. Jason Leavitt, Police Officer for District Heights, Md, and Prince George's County, Maryland David B. Mitchell, Prince George's County Police Chief Wayne Cheney, Police Officer City of District Heights, Md Michael Conboy, Police Chief for District Heights, Md, Dorothy C. Elliott, Individually and as Co-Personal Representative of the Estate of Archie Elliott, III Archie Elliott, Jr., Individually and as Co-Personal Representative of the Estate of Archie Elliott, III v. Wayne Cheney, Police Officer, and Jason Leavitt, Police Officer for District Heights, Md Prince George's County, Maryland David B. Mitchell, Prince George's County Police Chief City of District Heights, Md Michael Conboy, Police Chief for District Heights, Md · Elliott III
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.