Defendant’s arrest for a parole violation while he was standing next to his vehicle resulted in a search of the person finding drugs, and that justified a search incident of the vehicle, too. Badyrka v. State, 2024 Tex. App. LEXIS 130 (Tex. App. – Houston (1st Dist.) Jan. 9, 2024).
Even without the allegedly false statements, probable cause remains on the totality for the warrant. United States v. Sleva, 2024 U.S. Dist. LEXIS 3773 (M.D. Pa. Jan. 5, 2024).*
It was clearly established that a warrantless arrest outside the home cannot lawfully move inside the home without exigent circumstances. Bailey v. Swindell, 2024 U.S. App. LEXIS 517 (11th Cir. Jan. 8, 2024), prior appeal Bailey v. Swindell, 940 F.3d 1295 (11th Cir. 2019).*
With no Ohio cases on point, looking to federal cases, the court concludes that running the passenger’s ID too was incidental to the stop and didn’t unreasonably extend it. State v. Foti, 2024-Ohio-39, 2024 Ohio App. LEXIS 47 (11th Dist. Jan. 8, 2024).
There was reasonable suspicion for the search of defendant’s cell phone and papers at the border at JFK airport. United States v. Gavino, 2024 U.S. Dist. LEXIS 3120 (E.D.N.Y. Jan. 7, 2024).*
“The Court finds the tip did not provide law enforcement with reasonable suspicion that the occupants of the vehicle were engaged in drug trafficking at the time and/or the vehicle contained drugs because the tip supplied only vaguely predictive information about future events and was not corroborated by the officers’ observations.” What happened later, however, provided reasonable suspicion. United States v. Howard, 2024 U.S. Dist. LEXIS 2963 (D. Mont. Jan. 5, 2024).*
Posted inCell phones, Informant hearsay|Comments Off on OH11: Running passenger’s ID through database didn’t violate Rodriguez
Reason: Study Estimates Roadside Drug Tests Result in 30,000 Wrongful Arrests Every Year by C.J. Ciaramella (“Roughly 30,000 people every year may be getting wrongfully arrested and jailed because of police departments’ widespread use of unreliable roadside field tests for drugs, according to a study released today by the Quattrone Center for the Fair Administration of Justice at the University of Pennsylvania.”)
A parole violation warrant permits a search incident to the arrest. United States v. Henderson, 2024 U.S. App. LEXIS 362 (6th Cir. Jan. 4, 2024) (applying Michigan law) (and after all, the defendant’s going to jail).
Stopping with the front wheels pointed out from the curb, tinted windows, and nervousness was not reasonable suspicion. Suppressed. United States v. Yates, 2024 U.S. Dist. LEXIS 2934 (N.D. Cal. Jan. 5, 2024).*
Defendant’s Franks challenge fails. “Anderson has done a laudable job of uncovering mistakes and incorrect information contained in the search warrant affidavit as well as omitted information he believes is material and should have been included. The Government argues that the Defendant’s method of isolating pieces of evidence in the affidavit and attacking the sufficiency of each piece of evidence individually ignores the totality of the circumstances analysis that governs the probable cause determination.” “The Court agrees with the Government that TFO Compton interpreted the facts as they were observed and drew reasonable conclusions based on his training and experience in drug trafficking.” Denied. United States v. Anderson, 2024 U.S. Dist. LEXIS 2641 (N.D. Ind. Jan. 5, 2024).*
Posted inUncategorized|Comments Off on CA6: Arrest on a PV warrant permits search incident
The trial court conducted a de novo review of the search warrant application, not seeing whether there was a substantial basis for finding probable cause. This was error. State v. Freeman, 2024 Fla. App. LEXIS 115 (Fla. 6th DCA Jan. 5, 2024).
Anticipating flight, spike strips were placed in front of defendant’s car, and he took off. “On these facts, the undersigned finds that it does not matter whether the use of spike strips constitutes a seizure per se for Fourth Amendment purposes. The police had more than sufficient reasonable suspicion to lawfully stop the Infiniti before it crossed the spike strips.” United States v. Washington, 2023 U.S. Dist. LEXIS 231754 (E.D. Mo. Nov. 9, 2023).*
The officer was on the phone and thought that defendant’s tag light was out, and that was the basis for the stop. The video, however, was inconclusive. The court finds the officer not credible because he withheld information about being on the phone from one hearing to the next. Motion to suppress granted. United States v. Weaver, 2024 U.S. Dist. LEXIS 2671 (N.D. Miss. Jan. 5, 2024).*
“I conclude that a law enforcement officer’s activation of red and blue emergency does not, by itself, establish a seizure for Fourth Amendment purposes. However, it is a factor that weighs in favor of finding a seizure. Certain other facts weigh against a finding of seizure. For example, Diaz was sitting in a truck that appeared to be wrecked. Gov. Ex. 5 at 1:28-1:35 (Diaz explaining to Clausen that the truck had been in the impound lot due to a wreck). Reasonable persons sitting in a vehicle in disrepair in the middle of winter could assume that the officer is approaching to check on their welfare.” United States v. Diaz, 2024 U.S. Dist. LEXIS 2607 (N.D. Iowa Jan. 5, 2024).
Defendant’s Franks challenge fails. “Anderson has done a laudable job of uncovering mistakes and incorrect information contained in the search warrant affidavit as well as omitted information he believes is material and should have been included. The Government argues that the Defendant’s method of isolating pieces of evidence in the affidavit and attacking the sufficiency of each piece of evidence individually ignores the totality of the circumstances analysis that governs the probable cause determination.” “The Court agrees with the Government that TFO Compton interpreted the facts as they were observed and drew reasonable conclusions based on his training and experience in drug trafficking.” Denied. United States v. Anderson, 2024 U.S. Dist. LEXIS 2641 (N.D. Ind. Jan. 5, 2024).*
Posted inFranks doctrine, Seizure|Comments Off on N.D.Iowa: Police car pulling up with activated blue and red lights wasn’t necessarily a seizure; here, it is not
An Ohio municipal court does not have authority to issue a search warrant for collection of records from out of state. State v. Worthan, 2024-Ohio-21, 2024 Ohio App. LEXIS 33 (2d Dist. Jan. 5, 2024).
Defendant approached the officers and wasn’t seized until they told him to stay there. There was reasonable suspicion at that point. The owner of the car was called to come and get it. The search of the car was reasonable under the automobile exception. United States v. Mitchell, 2024 U.S. Dist. LEXIS 2454 (D.D.C. Jan. 5, 2024).*
“[P]olice had probable cause to arrest Jackson because the facts, known to police at the time of the arrest, establish that Jackson (1) was a passenger in a vehicle stopped, in a high-crime area, for having improper tags; (2) fled after police stopped the vehicle; (3) did not comply with the officer’s commands to stop; (4) discarded a liquor bottle; and (5) gripped his waistband in a manner that appeared as if he were concealing a weapon.” United States v. Jackson, 2024 U.S. App. LEXIS 259 (11th Cir. Jan. 5, 2024).*
Jailers intercepted a jail call between an inmate and a confederate outside who was told to move the drugs from his house. Police surveilled the house. When defendant showed up with a backpack and came out of the house, there was probable cause for his stop and seizure, including his car. State v. Martin, 2024-Ohio-10, 2024 Ohio App. LEXIS 37 (1st Dist. Jan. 5, 2024).
The early morning traffic stop was justified by reasonable suspicion of an offense, plus defendant said they were coming from a casino, but it was in the other direction. A drug dog was called for. The officer commented to backup about the statistics of the dog. The stop was pursued diligently, and there was no stall for the dog. Motion to suppress was properly denied. State v. Manns, 2024-Ohio-23 (2d Dist. Jan. 5, 2024).*
Defendant’s going from his home to the controlled buy and back was probable cause for the home. The good faith exception applies too. United States v. Day, 2023 U.S. Dist. LEXIS 231761 (D. Minn. Nov. 6, 2023),* adopted, 2024 U.S. Dist. LEXIS 754 (D.Minn. Jan. 3, 2024).*
WaPo: Google location data was used to find Jan. 6 rioters. It’s disappearing. by Rachel Weiner and Drew Harwell (“Special counsel Jack Smith has a plan for how to illustrate Donald Trump’s influence over the rioters who stormed the U.S. Capitol on Jan. 6, 2021. Prosecutors will show a map of people gathered around the Ellipse to hear Trump say, ‘we’re going to the Capitol’ to ‘fight like hell,’ then follow those supporters in real time as they head down Pennsylvania Avenue to where lawmakers were certifying President Biden’s victory. That visualization, detailed in court filings in Trump’s federal election subversion case in D.C., was created with data from Google. But the tool that has pitted law enforcement investigative priorities against personal privacy concerns soon won’t be so accessible. The company will no longer store location history that was used to identify hundreds of people who stormed the Capitol on Jan. 6 and to prosecute the man those rioters hoped to keep in power.”)
Posted inGeolocation data|Comments Off on WaPo: Google location data was used to find Jan. 6 rioters. It’s disappearing.
Defendant was a passenger in a rideshare, and the car was stopped for a traffic offense. They were all ordered out, and defendant took off his jacket while “blading,” said the officer, and left it in the car. The officer frisked the jacket finding a gun. The frisk of the jacket was without reasonable suspicion, and the gun should have been suppressed. Champion v. United States, 2024 D.C. App. LEXIS 2 (Jan. 4, 2024) (2-1) (argued 10/14/20 but decided 1/4/24, 3 years, 2 months, 3 weeks later; and they aren’t even embarrassed).
An inoperable headlight is reasonable suspicion for a traffic stop. State v. Kancler, 2024-Ohio-16, 2024 Ohio App. LEXIS 17 (8th Dist. Jan. 4, 2024).*
Defendant was arrested for an apparent hand-to-hand drug transaction, and he was handcuffed. His backpack was searched, too, and this was valid as an inventory because he was going to jail. United States v. Velazquez, 2024 U.S. Dist. LEXIS 1690 (D.N.J. Jan. 4, 2024).*
Officers entered the stairwell up to defendant’s second floor apartment. It was contended that the entry was unreasonable because the stairwell was part of defendant’s tenancy. At the top of the stairs, however, officers knocked and gained consent to enter. The occupants had a history of running, and an officer was out back, just in case. “Finally, although it does not purge the illegality of the officers’ entrance into the stairwell of defendant’s apartment, it is relevant to the attenuation analysis that there was a second door at the top of the stairway separating the interior of defendant’s apartment. This is not a case where police officers entered directly into the main area of defendant’s apartment and began searching, but rather they had to stop, knock and seek consent from defendant prior to entering the main living area of the apartment …. Thus, given that there ‘was no evidence that the illegal entry was undertaken for the purpose of obtaining consent or seizing the fruits of the search …, the alleged police misconduct here — walking through an unlocked [first floor] door into a [stairwell], before knocking on an interior door — is not so flagrantly intrusive on personal privacy that its taint cannot be dissipated.’.” People v. Crispell, 2024 NY Slip Op 00004, 2024 N.Y. App. Div. LEXIS 40 (3rd Dept. Jan. 4, 2024).
When there is a gun and the government wants to attempt to see if defendant’s DNA is on it, the cases go both ways: Should there be DNA on the gun first to compel defendant to submit to a DNA test? Here they didn’t know. Getting the warrant for DNA from defendant to see if it matches DNA not yet looked for is reasonable and done in good faith. United States v. Alvin, 2023 U.S. Dist. LEXIS 231598 (S.D. Fla. Dec. 15, 2023) (R&R).*
Posted inAttenuation, Exclusionary rule|Comments Off on NY3: Entry into def’s stairwell was apparently illegal, but officers knocked at the door at the top of the stairs and got consent; this was attenuated
Acting on a tip, officers did a dog sniff of defendant’s covered car parked in his driveway, and they used that to get a warrant for it. Collins didn’t come along until the following year. The officers laid it all out, and the issuing judge signed off on the warrant. It was all done in good faith. United States v. Hernandez, 2024 U.S. App. LEXIS 189 (2d Cir. Jan. 4, 2024).
The 911 dispatcher could see defendant “messing with a jail window,” so he called for deputies. Defendant saw them and ran. That was reasonable suspicion. State v. Wilburn, 2023-Ohio-4865 (4th Dist. Dec. 21, 2023).*
The warrant was not based on stale information, and it was issued with apparent probable cause and executed in good faith. United States v. Fitzpatrick, 2024 U.S. Dist. LEXIS 1362 (N.D.W.Va. Jan. 3, 2024).*
The state issued warrant here authorized the use of a cell site simulator, but this wasn’t explicitly stated in the affidavit for warrant. And, the affidavit wasn’t incorporated into the warrant either. This is a close question. The court comes down on the side of the warrant permitting this. “The language in the search warrant itself referring to location technology devices, available location technology, cell site information, and ‘any other available precision location information’ is broad enough to include cell-site information, though it would have been the better practice to specify that a cell-site simulator might be used, rather than describing general categories of investigative techniques that include the use of cell-site simulators.” Moreover, the good faith exception applies. United States v. Bennett, 2023 U.S. Dist. LEXIS 231654 (D. Minn. Nov. 7, 2023), adopted, 2024 U.S. Dist. LEXIS 100 (D.Minn. Jan. 2, 2024).
Police showed up to execute a search warrant as defendant was about to leave for vacation in Mexico. He said he was leaving then, and one said “You’re not going anywhere.” “Defendant being questioned in the comfort of his own home, with no physical threat to his liberty or safety, weighs heavily in favor of a finding that Defendant was not in custody.” No handcuffs, no drawn weapons, white-collar fraud warrant. United States v. Carver, 2024 U.S. Dist. LEXIS 1256 (E.D.N.Y. Jan. 3, 2024).*
Defendant’s objection to the R&R isn’t enough to overrule the USMJ’s finding there was probable cause. Defendant presents a trial defense, not a defense to probable cause. United States v. Cole, 2024 U.S. Dist. LEXIS 752 (D. Minn. Jan. 3, 2024).*
Habeas petitioner raised his Fourth Amendment ineffective assistance of counsel claim in the state courts and the found that they search was valid and not ineffective assistance. These are not unreasonable applications of the law. Crain v. Warden, 2024 U.S. Dist. LEXIS 928 (N.D. Ind. Jan. 3, 2024).*
The evidence on summary judgment did not support exigency to remove a four-year-old child from the home without a court order. Banks v. Herbrich, 2024 U.S. App. LEXIS 135 (5th Cir. Jan. 3, 2024).*
A search warrant affidavit is evaluated for probable cause based on what it contains, not what it lacks. United States v. Daigle, 947 F.3d 1076, 1081 (8th Cir. 2020). Moreover, the good faith exception applies. There was enough information to show probable cause, and it was not wholly lacking in information. United States v. Burns, 2023 U.S. Dist. LEXIS 231595 (D. Neb. Nov. 28, 2023) (R&R).
Defendant’s traveling from home to the controlled buy and back home was nexus to his home. United States v. Day, 2024 U.S. Dist. LEXIS 754 (D. Minn. Jan. 3, 2024).*
The gun was in plain view in the car with a Glock switch that was also immediately apparent, as was defendant being a felon. The validity of the warrant need not even be decided. United States v. Roberts, 2023 U.S. Dist. LEXIS 231539 (W.D. Tenn. Nov. 15, 2023).*
A driveway shared with the house next door was not curtilage. A driveway in a city usually isn’t anyway. United States v. Vasquez, 2024 U.S. App. LEXIS 75 (10th Cir. Jan. 3, 2024).
Defendant’s objection to the R&R that the occupant of the home was hiding drugs before the warrant was executed didn’t undermine the probable cause as to defendant. United States v. Cole, 2024 U.S. Dist. LEXIS 752 (D. Minn. Jan. 3, 2024).*
Defendant was arrested at the Cincinnati/Northern Kentucky airport on a warrant. The later search of his wallet was valid as search incident. United States v. Myers, 2024 U.S. Dist. LEXIS 1045 (S.D. Ohio Jan. 3, 2024).*
Defendant was a squatter in a building with posted sign warning it was substandard and unsafe. He had no reasonable expectation of privacy in the premises. United States v. Guzman, 2024 U.S. Dist. LEXIS 550 (D.N.M. Jan. 2, 2024).
Michael Cohen’s Bivens claim of retaliatory arrest presents a new context, and post-Bivens cases all counsel against extending it to this situation, too. Cohen v. Trump, 2024 U.S. App. LEXIS 7 (2d Cir. Jan. 2, 2024).
The officer’s misstatement as to where defendant’s gun was found was a mere mistake and not intended to mislead. The USMJ finds the officer otherwise credible, and the warrant was based on probable cause. United States v. Roberts, 2023 U.S. Dist. LEXIS 231539 (W.D. Tenn. Nov. 15, 2023),* adopted, 2024 U.S. Dist. LEXIS 502 (W.D. Tenn. Jan. 2, 2024).*
When you live with a probationer with a Fourth Amendment waiver, your stuff in the premises is likely subject to search, too. Here, it’s decided on defendant’s failure to object to his alleged implied consent [like he knew he could] or the PO’s exceeding his authority [not developed below or here]. Martin v. State, 2024 Ga. App. LEXIS 1 (Jan. 2, 2024).
Appellant’s claim that seizure of property to levy on a civil judgment was a Fourth Amendment violation wasn’t raised in the trial court, so it’s not considered on appeal. Turnbull-Wheatley v. Turnbull, 2023 VI 17, 2023 V.I. Supreme LEXIS 23 (Dec. 29, 2023).*
The probable cause showing for this warrant was sufficient for a reasonable belief the warrant was valid so the good faith exception applies, too. United States v. Burns, 2024 U.S. Dist. LEXIS 112 (D. Neb. Jan. 2, 2024).*
Posted inGood faith exception, Seizure|Comments Off on GA: Probationer’s housemate didn’t object to probation search, so it was valid as to him, too
Here there were two search warrants: One for suite E and another for both suites D & E to be sure they were searching the right premises. Execution of the suite E warrant led officers to get another for both. (a) Then, the suite E warrant was accidently destroyed. The trial court found that it existed at the time of the search and was valid, and it was destroyed without bad faith. (b) The execution of the warrant was reasonable and the search was valid. (c) The issuing judge wrote in the time of the first warrant because he thought it related back. The failure to have the exact time for the combined warrant was neither error nor bad faith. (d) Two affiants were listed in the affidavit but only one appeared to sign it. This also was not error because it was signed under oath. Moore v. State, 2024 Miss. App. LEXIS 1 (Jan. 2, 2024):
Posted inReasonableness, Warrant execution, Warrant papers|Comments Off on MS: One of two SWs for def’s business was accidentally destroyed but not in bad faith; officers getting second SW were justified
Defendant was on parole for felony DUI when he became a suspect in a child pornography case. His parole officer authorized a search of his computer hard drive for child pornography, and defense counsel wasn’t ineffective for not challenging the lack of a warrant. State v. Carter, 2023 S.D. 67, 2023 S.D. LEXIS 143 (Dec. 28, 2023). [This shows just how sweeping the probation and parole search authority can be.]
Defendant’s car, suspected in a home invasion robbery, was searched by his wife’s consent, and a bank robbery note was found. He said she hardly ever drove it. “Here, both Defendant and his wife had mutual use of the property by virtue of joint access. M.H. purchased the vehicle, was the registered owner and insurance policyholder, made the vehicle’s monthly payments, drove it several times, had access to a spare key, had joint property in the vehicle (a child’s car seat), was the sole person who could retrieve the vehicle after its impoundment, and subsequently sold it.” United States v. Candelaria, 2023 U.S. Dist. LEXIS 231032 (D.N.M. Dec. 28, 2023).*
A license plate frame that partially obscured the state’s name was not an offense, so the stop was invalid. The officer knew it was a Nevada plate by looking at it, and he could run the information. Otherwise, it lends to arbitrary enforcement. McCord v. State, 2023 Nev. LEXIS 50 (Dec. 28, 2023).*
"If it was easy, everybody would be doing it. It isn't, and they don't." —Me
"Life is not a matter of holding good cards, but of playing a poor hand well." –Josh Billings (pseudonym of Henry Wheeler Shaw), Josh Billings on Ice, and Other Things (1868) (erroneously attributed to Robert Louis Stevenson, among others)
“I am still learning.” —Domenico Giuntalodi (but misattributed to Michelangelo Buonarroti (common phrase throughout 1500's)).
"Love work; hate mastery over others; and avoid intimacy with the government."
—Shemaya, in the Thalmud
"It is a pleasant world we live in, sir, a very pleasant world. There are bad people in it, Mr. Richard, but if there were no bad people, there would be no good lawyers."
—Charles Dickens, “The Old Curiosity Shop ... With a Frontispiece. From a Painting by Geo. Cattermole, Etc.” 255 (1848)
"A system of law that not only makes certain conduct criminal, but also lays down rules for the conduct of the authorities, often becomes complex in its application to individual cases, and will from time to time produce imperfect results, especially if one's attention is confined to the particular case at bar. Some criminals do go free because of the necessity of keeping government and its servants in their place. That is one of the costs of having and enforcing a Bill of Rights. This country is built on the assumption that the cost is worth paying, and that in the long run we are all both freer and safer if the Constitution is strictly enforced." —Williams v. Nix, 700 F. 2d 1164, 1173 (8th Cir. 1983) (Richard Sheppard Arnold, J.), rev'd Nix v. Williams, 467 US. 431 (1984).
"The criminal goes free, if he must, but it is the law that sets him free. Nothing can destroy a government more quickly than its failure to observe its own laws, or worse, its disregard of the charter of its own existence." —Mapp v. Ohio, 367 U.S. 643, 659 (1961).
"Any costs the exclusionary rule are costs imposed directly by the Fourth Amendment."
—Yale Kamisar, 86 Mich.L.Rev. 1, 36 n. 151 (1987).
"There have been powerful hydraulic pressures throughout our history that bear heavily on the Court to water down constitutional guarantees and give the police the upper hand. That hydraulic pressure has probably never been greater than it is today." — Terry v. Ohio, 392 U.S. 1, 39 (1968) (Douglas, J., dissenting).
"The great end, for which men entered into society, was to secure their property." —Entick v. Carrington, 19 How.St.Tr. 1029, 1066, 95 Eng. Rep. 807 (C.P. 1765)
"It is a fair summary of history to say that the safeguards of liberty have frequently been forged in controversies involving not very nice people. And so, while we are concerned here with a shabby defrauder, we must deal with his case in the context of what are really the great themes expressed by the Fourth Amendment." —United States v. Rabinowitz, 339 U.S. 56, 69 (1950) (Frankfurter, J., dissenting)
"The course of true law pertaining to searches and seizures, as enunciated here, has not–to put it mildly–run smooth." —Chapman v. United States, 365 U.S. 610, 618 (1961) (Frankfurter, J., concurring).
"A search is a search, even if it happens to disclose nothing but the bottom of a turntable." —Arizona v. Hicks, 480 U.S. 321, 325 (1987)
"For the Fourth Amendment protects people, not places. What a person knowingly exposes to the public, even in his own home or office, is not a subject of Fourth Amendment protection. ... But what he seeks to preserve as private, even in an area accessible to the public, may be constitutionally protected." —Katz v. United States, 389 U.S. 347, 351 (1967)
“Experience should teach us to be most on guard to protect liberty when the Government’s purposes are beneficent. Men born to freedom are naturally alert to repel invasion of their liberty by evil-minded rulers. The greatest dangers to liberty lurk in insidious encroachment by men of zeal, well-meaning but without understanding.” —United States v. Olmstead, 277 U.S. 438, 479 (1925) (Brandeis, J., dissenting)
“Liberty—the freedom from unwarranted intrusion by government—is as easily lost through insistent nibbles by government officials who seek to do their jobs too well as by those whose purpose it is to oppress; the piranha can be as deadly as the shark.” —United States v. $124,570, 873 F.2d 1240, 1246 (9th Cir. 1989)
"You can't always get what you want / But if you try sometimes / You just might find / You get what you need." —Mick Jagger & Keith Richards, Let it Bleed (album, 1969)
"In Germany, they first came for the communists, and I didn't speak up because I wasn't a communist. Then they came for the Jews, and I didn't speak up because I wasn't a Jew. Then they came for the trade unionists, and I didn't speak up because I wasn't a trade unionist. Then they came for the Catholics and I didn't speak up because I wasn't a Catholic. Then they came for me–and by that time there was nobody left to speak up."
—Martin Niemöller (1945) [he served seven years in a concentration camp]
“Children grow up thinking the adult world is ordered, rational, fit for purpose. It’s crap. Becoming a man is realising that it’s all rotten. Realising how to celebrate that rottenness, that’s freedom.” – John le Carré, The Night Manager (1993), line by Richard Roper
"The point of the Fourth Amendment, which often is not grasped by zealous officers, is not that it denies law enforcement the support of the usual inferences which reasonable men draw from evidence. Its protection consists in requiring that those inferences be drawn by a neutral and detached magistrate instead of being judged by the officer engaged in the often competitive enterprise of ferreting out crime." —Johnson v. United States, 333 U.S. 10, 13-14 (1948)
The book was dedicated in the first (1982) and sixth (2025) editions to Justin William Hall (1975-2025). He was three when this project started in 1978.
