Case Citator › Horton v. California

Horton v. California

Is it still good law? What later courts have actually done to this case.

Criticized by some courts
Court
Supreme Court of the United States
Citation
496 U.S. 128
Decided
Confirmed treatments
1
Flagged citations read
284 of 284
Citing cases (total)
2,919
Treatment dates
1990
Criticized by some courts
At least one reviewed court has criticized this case’s reasoning. No reviewed court has overruled it. Horton v. California has been criticized: all 284 flagged citations have been read, and the one confirmed adverse treatment is listed above. The Hawaiʻi Supreme Court retained inadvertence under its state constitution despite Horton's contrary federal rule, while People v. Manganaro criticized Horton's physical-intrusion focus.
More on how this was screened

The other opinions positively applied Horton's federal plain-view doctrine or described Horton as abrogating older cases and requirements.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

2,919 later cases cite Horton v. California; 284 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Horton v. California?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Criticized

  • The court criticized Horton's plain-view formulation as incomplete because it focused on physical intrusions and discounted privacy-invading observation by a lawfully positioned officer.

    People v. Manganaro · New York Supreme Court · filed

    The Horton formulation seems to suggest that, in the plain view context, a Fourth Amendment violation can occur only in the way the officer gets to the position from which the observation is made or in the way the officer gains access to the evidence plainly viewed. Thus, the court appears to look only to physical intrusions, discounting the possibility that a lawfully positioned officer may nevertheless invade privacy through the observation itself. In that respect, the Horton framework seems incomplete.
    Read the full opinion on CourtListener →

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