Katz test (Maryland) · Go Syfert
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Katz test in Maryland

15 Maryland opinions name it 2 courts 2001–2025 1 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (14)

CaseFollowedCited
United States v. Jonesgreen
scotus · 2012 · cited in 5 Maryland opinions naming this issue, 2012–2017
2 sentences

2017In a separate concurrence, Justice Sotomayor, who joined the five-justice majority subscribing to the trespass theory, warned that "GPS monitoi'ing generates a precise, comprehensive record of a person's public movements that reflects a wealth of detail about her familial, political, professional, religious, and sexual associations,” She nevertheless conceded that “the same technological advances that have made possible nontrespassory surveillance techniques will also affect the Katz test by shaping the evolution of societal privacy expectations.” 565 U.S. at 415 , 132 S.Ct. 945 (Sotomayor, J.

2017In a separate concurrence, Justice Sotomayor, who joined the five-justice majority subscribing to the trespass theory, warned that "GPS monitoi'ing generates a precise, comprehensive record of a person's public movements that reflects a wealth of detail about her familial, political, professional, religious, and sexual associations,” She nevertheless conceded that “the same technological advances that have made possible nontrespassory surveillance techniques will also affect the Katz test by shaping the evolution of societal privacy expectations.” 565 U.S. at 415 , 132 S.Ct. 945 (Sotomayor, J.

45
Katz v. United Statesgreen
scotus · 1967 · cited in 5 Maryland opinions naming this issue, 2001–2016
2 sentences

2016In determining then whether a Fourth Amendment “search” occurred, we apply the court’s factual findings to the test pronounced in Katz, supra. Rather than limit the constitutional appraisal to a trespass analysis, 13 the Katz test requires a two-fold showing: “first that a person have exhibited an actual (subjective) expectation of privacy and, second, that the expectation be one that society is prepared to recognize as *381 ‘reasonable.’” 389 U.S. at 361 , 88 S.Ct. 507 (Harlan, J., concurring). 14 Even under the more flexible Katz test, however, rapid advancements in technology make ascertain

2016In determining then whether a Fourth Amendment “search” occurred, we apply the court’s factual findings to the test pronounced in Katz, supra. Rather than limit the constitutional appraisal to a trespass analysis, 13 the Katz test requires a two-fold showing: “first that a person have exhibited an actual (subjective) expectation of privacy and, second, that the expectation be one that society is prepared to recognize as *381 ‘reasonable.’” 389 U.S. at 361 , 88 S.Ct. 507 (Harlan, J., concurring). 14 Even under the more flexible Katz test, however, rapid advancements in technology make ascertain

25
Walker v. Stategreen
md · 2013 · cited in 2 Maryland opinions naming this issue, 2014–2025
2 sentences

2025Walker, 432 Md. at 605 (referring to the Katz test).

2025Walker, 432 Md. at 605 (referring to the Katz test).

22
Kyllo v. United Statesgreen
scotus · 2001 · cited in 2 Maryland opinions naming this issue, 2014–2016
2 sentences

2016The Court then noted that, although the Katz test — “whether the individual has an expectation of privacy that society is prepared to recognize as reasonable” — may be difficult to apply to some locations, such as telephone booths and automobiles — the expectation of privacy in the home had “roots deep in the common law.” Id. at 34, 121 S.Ct. 2038 . *385 In support of the use of its thermal imaging technology, the government in Kyllo argued that there was no “search” because the device detected “ ‘only heat radiating from the external surface of the house[.]’ ” Id. at 35 , 121 S.Ct. 2038 .

2016The Court then noted that, although the Katz test — “whether the individual has an expectation of privacy that society is prepared to recognize as reasonable” — may be difficult to apply to some locations, such as telephone booths and automobiles — the expectation of privacy in the home had “roots deep in the common law.” Id. at 34, 121 S.Ct. 2038 . *385 In support of the use of its thermal imaging technology, the government in Kyllo argued that there was no “search” because the device detected “ ‘only heat radiating from the external surface of the house[.]’ ” Id. at 35 , 121 S.Ct. 2038 .

12
Corbin v. Stategreen
md · 2012 · cited in 2 Maryland opinions naming this issue, 2013–2014
2 sentences

2014See, e.g., Kyllo v. United States, 533 U.S. 27, 33 , 121 S.Ct. 2038 , 150 L.Ed.2d 94 (2001) (“[A] Fourth Amendment search occurs when the government violates a subjective expectation of privacy that society recognizes as reasonable.”). 7 The Katz test consists of two parts, “each of which must be satisfied in order for the Fourth Amendment to apply: (1) a defendant must ‘demonstrate an actual, subjective expectation of privacy in the item or place searched’ and (2) ‘prove that the expectation is one that society is prepared to recognize as reasonable.’ ” Walker, 432 Md. at 605 , 69 A.3d 1066 (

2014See, e.g., Kyllo v. United States, 533 U.S. 27, 33 , 121 S.Ct. 2038 , 150 L.Ed.2d 94 (2001) (“[A] Fourth Amendment search occurs when the government violates a subjective expectation of privacy that society recognizes as reasonable.”). 7 The Katz test consists of two parts, “each of which must be satisfied in order for the Fourth Amendment to apply: (1) a defendant must ‘demonstrate an actual, subjective expectation of privacy in the item or place searched’ and (2) ‘prove that the expectation is one that society is prepared to recognize as reasonable.’ ” Walker, 432 Md. at 605 , 69 A.3d 1066 (

12
Attorney Grievance Commission v. Hoanggreen
md · 2013 · cited in 1 Maryland opinions naming this issue, 2015–2015
2 sentences

2015Whether Katz Violated MLRPC 8.4(a) And (d) Katz also takes exception to the hearing judge’s proposed conclusions that he violated MLRPC 8.4(a) and (d). “[I]t is well-settled that a lawyer’s willful failure to file his or her personal income tax returns violates the prohibition of [MLRPC] 8.4(d) of engaging in conduct prejudicial to the administration of justice.” Att’y Grievance Comm’n v. Hoang, 433 Md. 600, 610 , 72 A.3d 548, 554 (2013) (citation omitted).

2015Whether Katz Violated MLRPC 8.4(a) And (d) Katz also takes exception to the hearing judge’s proposed conclusions that he violated MLRPC 8.4(a) and (d). “[I]t is well-settled that a lawyer’s willful failure to file his or her personal income tax returns violates the prohibition of [MLRPC] 8.4(d) of engaging in conduct prejudicial to the administration of justice.” Att’y Grievance Comm’n v. Hoang, 433 Md. 600, 610 , 72 A.3d 548, 554 (2013) (citation omitted).

11
McFarlin v. Stategreen
md · 2009 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014“A person demonstrates a subjective expectation of privacy by showing that he or she sought ‘to preserve something as private.’ ” Williamson, 413 Md. at 535 , 993 A.2d 626 (quoting McFarlin v. State, 409 Md. 391, 404 , 975 A.2d 862 (2009)).

2014“A person demonstrates a subjective expectation of privacy by showing that he or she sought ‘to preserve something as private.’ ” Williamson, 413 Md. at 535 , 993 A.2d 626 (quoting McFarlin v. State, 409 Md. 391, 404 , 975 A.2d 862 (2009)).

11
Williamson v. Stategreen
md · 2010 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Kyllo v. United States, 533 U.S. 27, 33 , 121 S.Ct. 2038 , 150 L.Ed.2d 94 (2001) (“[A] Fourth Amendment search occurs when the government violates a subjective expectation of privacy that society recognizes as reasonable.”). 7 The Katz test consists of two parts, “each of which must be satisfied in order for the Fourth Amendment to apply: (1) a defendant must ‘demonstrate an actual, subjective expectation of privacy in the item or place searched’ and (2) ‘prove that the expectation is one that society is prepared to recognize as reasonable.’ ” Walker, 432 Md. at 605 , 69 A.3d 1066 (

2014See, e.g., Kyllo v. United States, 533 U.S. 27, 33 , 121 S.Ct. 2038 , 150 L.Ed.2d 94 (2001) (“[A] Fourth Amendment search occurs when the government violates a subjective expectation of privacy that society recognizes as reasonable.”). 7 The Katz test consists of two parts, “each of which must be satisfied in order for the Fourth Amendment to apply: (1) a defendant must ‘demonstrate an actual, subjective expectation of privacy in the item or place searched’ and (2) ‘prove that the expectation is one that society is prepared to recognize as reasonable.’ ” Walker, 432 Md. at 605 , 69 A.3d 1066 (

11
Attorney Grievance Commission of Maryland v. Thomasgreen
md · 2010 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Kyllo v. United States, 533 U.S. 27, 33 , 121 S.Ct. 2038 , 150 L.Ed.2d 94 (2001) (“[A] Fourth Amendment search occurs when the government violates a subjective expectation of privacy that society recognizes as reasonable.”). 7 The Katz test consists of two parts, “each of which must be satisfied in order for the Fourth Amendment to apply: (1) a defendant must ‘demonstrate an actual, subjective expectation of privacy in the item or place searched’ and (2) ‘prove that the expectation is one that society is prepared to recognize as reasonable.’ ” Walker, 432 Md. at 605 , 69 A.3d 1066 (

2014See, e.g., Kyllo v. United States, 533 U.S. 27, 33 , 121 S.Ct. 2038 , 150 L.Ed.2d 94 (2001) (“[A] Fourth Amendment search occurs when the government violates a subjective expectation of privacy that society recognizes as reasonable.”). 7 The Katz test consists of two parts, “each of which must be satisfied in order for the Fourth Amendment to apply: (1) a defendant must ‘demonstrate an actual, subjective expectation of privacy in the item or place searched’ and (2) ‘prove that the expectation is one that society is prepared to recognize as reasonable.’ ” Walker, 432 Md. at 605 , 69 A.3d 1066 (

11
Florida v. Jardinesgreen
scotus · 2013 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014Indeed, the Jones Court made clear that “we do not make trespass the exclusive test” and “where a classic trespassory search is not involved ... resort must be had to Katz analysis.” 132 S.Ct. at 953-54 ; see also Florida v. Jardines, - U.S. -, 133 S.Ct. 1409, 1417 , 185 L.Ed.2d 495 (2013) (stating that "[t]he Katz reasonable-expectations test ‘has been added to ... ’ the traditional property-based understanding of the Fourth Amendment”) (quoting Jones, 132 S.Ct. at 952 ). .

2014Indeed, the Jones Court made clear that “we do not make trespass the exclusive test” and “where a classic trespassory search is not involved ... resort must be had to Katz analysis.” 132 S.Ct. at 953-54 ; see also Florida v. Jardines, - U.S. -, 133 S.Ct. 1409, 1417 , 185 L.Ed.2d 495 (2013) (stating that "[t]he Katz reasonable-expectations test ‘has been added to ... ’ the traditional property-based understanding of the Fourth Amendment”) (quoting Jones, 132 S.Ct. at 952 ). .

11
State v. Bridgesgreen
me · 1986 · cited in 1 Maryland opinions naming this issue, 2013–2013
2 sentences

2013See State v. Bridges, 513 A.2d 1365, 1367-68 (Me.1986) (defendants who made no effort to conceal their movements in a publicly visible location manifested no subjective expectation of privacy and therefore there was no need to consider the objective part of the Katz inquiry); State v. Ross, 49 S.W.3d 833, 843-44 (Tenn.2001) (observing that an individual may have an expectation of privacy in a motel room that society would recognize as reasonable, but under the facts of the case, concluding that the defendant had no subjective expectation of privacy after disclaiming any interest in a key to th

2013See State v. Bridges, 513 A.2d 1365, 1367-68 (Me.1986) (defendants who made no effort to conceal their movements in a publicly visible location manifested no subjective expectation of privacy and therefore there was no need to consider the objective part of the Katz inquiry); State v. Ross, 49 S.W.3d 833, 843-44 (Tenn.2001) (observing that an individual may have an expectation of privacy in a motel room that society would recognize as reasonable, but under the facts of the case, concluding that the defendant had no subjective expectation of privacy after disclaiming any interest in a key to th

11
State v. Rossgreen
tenn · 2001 · cited in 1 Maryland opinions naming this issue, 2013–2013
2 sentences

2013See State v. Bridges, 513 A.2d 1365, 1367-68 (Me.1986) (defendants who made no effort to conceal their movements in a publicly visible location manifested no subjective expectation of privacy and therefore there was no need to consider the objective part of the Katz inquiry); State v. Ross, 49 S.W.3d 833, 843-44 (Tenn.2001) (observing that an individual may have an expectation of privacy in a motel room that society would recognize as reasonable, but under the facts of the case, concluding that the defendant had no subjective expectation of privacy after disclaiming any interest in a key to th

2013See State v. Bridges, 513 A.2d 1365, 1367-68 (Me.1986) (defendants who made no effort to conceal their movements in a publicly visible location manifested no subjective expectation of privacy and therefore there was no need to consider the objective part of the Katz inquiry); State v. Ross, 49 S.W.3d 833, 843-44 (Tenn.2001) (observing that an individual may have an expectation of privacy in a motel room that society would recognize as reasonable, but under the facts of the case, concluding that the defendant had no subjective expectation of privacy after disclaiming any interest in a key to th

11
Kee v. State Highway Administrationgreen
md · 1988 · cited in 1 Maryland opinions naming this issue, 2009–2009
2 sentences

2009The test for determining whether the legislature has waived a local government agency’s governmental immunity (applicable only to government functions) has two conditions: “First, the Legislature must authorize suits for damages, and second, there must be provision for the payment of judgments.” Kee, 313 Md. at 455 , 545 A.2d at 1317 (summarizing the Katz test).

2009The test for determining whether the legislature has waived a local government agency’s governmental immunity (applicable only to government functions) has two conditions: “First, the Legislature must authorize suits for damages, and second, there must be provision for the payment of judgments.” Kee, 313 Md. at 455 , 545 A.2d at 1317 (summarizing the Katz test).

11
Sproates v. Stategreen
mdctspecapp · 1984 · cited in 1 Maryland opinions naming this issue, 2006–2006
2 sentences

2006The Court of Appeals of Maryland has articulated the Katz principle by stating that “Lt]he scope of the protection afforded by the Fourth Amendment is defined in terms of the individual’s ‘legitimate expectation of privacy.’ ” Stanberry v. State, 343 Md. 720, 731 , 684 A.2d 823 (1996); see Sproates v. State, 58 Md.App. 547, 563 , 473 A.2d 1289 (1984) (describing the principle as a “legitimate or reasonable” expectation of privacy). 8 When the teachings of Katz and its progeny are applied to field sobriety tests, we must determine whether the State has intruded into an area where an individual

2006The Court of Appeals of Maryland has articulated the Katz principle by stating that “Lt]he scope of the protection afforded by the Fourth Amendment is defined in terms of the individual’s ‘legitimate expectation of privacy.’ ” Stanberry v. State, 343 Md. 720, 731 , 684 A.2d 823 (1996); see Sproates v. State, 58 Md.App. 547, 563 , 473 A.2d 1289 (1984) (describing the principle as a “legitimate or reasonable” expectation of privacy). 8 When the teachings of Katz and its progeny are applied to field sobriety tests, we must determine whether the State has intruded into an area where an individual

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
United States v. Knotts green
scotus · 1983
2 sentences

2016Agreeing with Justice Brennan’s concurrence in Knotts v. United States, Justice Scalia expounded that “ ‘when the Government does engage in physical intrusion of a constitutionally protected area in order to obtain information, that intrusion may constitute a violation of the Fourth Amendment.’ ” Id. at 951 (quoting Knotts, 460 U.S. 276, 286 , 103 S.Ct. 1081 , 75 L.Ed.2d 55 (1983)).

2016Agreeing with Justice Brennan’s concurrence in Knotts v. United States, Justice Scalia expounded that “ ‘when the Government does engage in physical intrusion of a constitutionally protected area in order to obtain information, that intrusion may constitute a violation of the Fourth Amendment.’ ” Id. at 951 (quoting Knotts, 460 U.S. 276, 286 , 103 S.Ct. 1081 , 75 L.Ed.2d 55 (1983)).

22012–2016
Smith v. Maryland red
scotus · 1979
2 sentences

2017Smith v. Maryland, 442 U.S. 735 , 99 S.Ct. 2577 , 61 L.Ed.2d 220 (1979); see Part I.A.2 of this opinion above, .

2017Smith v. Maryland, 442 U.S. 735 , 99 S.Ct. 2577 , 61 L.Ed.2d 220 (1979); see Part I.A.2 of this opinion above, .

12017–2017
Raynor v. State green
md · 2014
2 sentences

2015The Katz test, from Justice Harlan’s concurrence to Katz v. United States, 389 U.S. 347 , 88 S.Ct. 507 , 19 L.Ed.2d 576 (1967) (Harlan, J., concurring), remains the “lodestar for determining whether police conduct is a search for purposes of the Fourth Amendment.” Raynor, 440 Md. at 83 , 99 A.3d at 759 .

2015The Katz test, from Justice Harlan’s concurrence to Katz v. United States, 389 U.S. 347 , 88 S.Ct. 507 , 19 L.Ed.2d 576 (1967) (Harlan, J., concurring), remains the “lodestar for determining whether police conduct is a search for purposes of the Fourth Amendment.” Raynor, 440 Md. at 83 , 99 A.3d at 759 .

12015–2015
Stone v. State green
mdctspecapp · 2008
2 sentences

2013The Circuit Court denied the motion to suppress, explaining its ruling: I believe that the Stone [v. State, 178 Md.App. 428 , 941 A.2d 1238 (2008) ], case is the Maryland case that’s on point and that is supported by U.S. v. Knotts, for the proposition that the first question is, is there a reasonable expectation of privacy that society is prepared to recognize under the Katz test.

2013The Circuit Court denied the motion to suppress, explaining its ruling: I believe that the Stone [v. State, 178 Md.App. 428 , 941 A.2d 1238 (2008) ], case is the Maryland case that’s on point and that is supported by U.S. v. Knotts, for the proposition that the first question is, is there a reasonable expectation of privacy that society is prepared to recognize under the Katz test.

12013–2013
United States v. Maynard green
cadc · 2010
2 sentences

2012Id. at 949 (citing United States v. Maynard, 615 F.3d 544 (D.C.Cir.2010)).

2012Id. at 949 (citing United States v. Maynard, 615 F.3d 544 (D.C.Cir.2010)).

12012–2012
Venner v. State green
md · 1977
2 sentences

2011See also Katz v. United States, 389 U.S. 347, 361 , 88 S.Ct. 507 , 19 L.Ed.2d 576 (1967) (Harlan, J., concurring) (establishing two-prong test); Venner v. State, 279 Md. 47, 51-52 , 367 A.2d 949 (1977) (adopting the Katz test).

2011See also Katz v. United States, 389 U.S. 347, 361 , 88 S.Ct. 507 , 19 L.Ed.2d 576 (1967) (Harlan, J., concurring) (establishing two-prong test); Venner v. State, 279 Md. 47, 51-52 , 367 A.2d 949 (1977) (adopting the Katz test).

12011–2011
Rakas v. Illinois green
scotus · 1979
2 sentences

2011A legitimate expectation of privacy is one that has its source outside of the Fourth Amendment “either by reference to concepts of real or personal property law or to understandings that are recognized and permitted by society.” Rakas v. Illinois, 439 U.S. 128 , 143-44 n. 12, 99 S.Ct. 421 , 58 L.Ed.2d 387 (1978).

2011A legitimate expectation of privacy is one that has its source outside of the Fourth Amendment “either by reference to concepts of real or personal property law or to understandings that are recognized and permitted by society.” Rakas v. Illinois, 439 U.S. 128 , 143-44 n. 12, 99 S.Ct. 421 , 58 L.Ed.2d 387 (1978).

12011–2011
Bushek v. Washington Suburban Sanitary Commission green
mdd · 2001
2 sentences

2010Id. at 482 n. 2. 19 .

2010Id. at 482 n. 2. 19 .

12010–2010
Jackson v. Housing Opportunities Commission green
md · 1980
2 sentences

2009A housing authority has power ‘[t]o sue and be sued.’ The power is unqualified.” Id. at 124, 422 A.2d at 379 .

2009A housing authority has power ‘[t]o sue and be sued.’ The power is unqualified.” Id. at 124, 422 A.2d at 379 .

12009–2009
Stanberry v. State green
md · 1996
2 sentences

2006The Court of Appeals of Maryland has articulated the Katz principle by stating that “Lt]he scope of the protection afforded by the Fourth Amendment is defined in terms of the individual’s ‘legitimate expectation of privacy.’ ” Stanberry v. State, 343 Md. 720, 731 , 684 A.2d 823 (1996); see Sproates v. State, 58 Md.App. 547, 563 , 473 A.2d 1289 (1984) (describing the principle as a “legitimate or reasonable” expectation of privacy). 8 When the teachings of Katz and its progeny are applied to field sobriety tests, we must determine whether the State has intruded into an area where an individual

2006The Court of Appeals of Maryland has articulated the Katz principle by stating that “Lt]he scope of the protection afforded by the Fourth Amendment is defined in terms of the individual’s ‘legitimate expectation of privacy.’ ” Stanberry v. State, 343 Md. 720, 731 , 684 A.2d 823 (1996); see Sproates v. State, 58 Md.App. 547, 563 , 473 A.2d 1289 (1984) (describing the principle as a “legitimate or reasonable” expectation of privacy). 8 When the teachings of Katz and its progeny are applied to field sobriety tests, we must determine whether the State has intruded into an area where an individual

12006–2006

Statutes the citing opinions construe

MD § Md. Code Ann., Crim. Law § 3-602 (3) USC § 18u.s.c.2510 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 20 (1975–2020) MD 15 (2001–2025) CT 13 (2010–2025) FL 11 (1980–2015) NM 10 (1991–2015) NY 9 (1997–2022) PA 9 (1976–2025) OR 8 (1981–1988) MT 8 (1982–2021) OH 8 (1976–2025) IL 7 (1973–2025) IN 6 (1985–2017) WI 6 (1985–2024) AZ 6 (2009–2023) MI 5 (1991–2022) TN 5 (1980–2019) VA 4 (2014–2017) TX 4 (1983–2015) CO 4 (1986–2009) IA 4 (2021–2023) GA 4 (2011–2019) KY 3 (2006–2016) AK 3 (1984–2024) VT 3 (1983–1998) ME 3 (1982–1995) NH 3 (1973–1990) SD 3 (2005–2017) NC 2 (2014–2015) WA 2 (1981–2021) HI 2 (1996–2016) DE 2 (1998–2018) KS 2 (1987–2012) MN 2 (2014–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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