There’s no constitutional requirement that the informant’s controlled buy be on video to support probable cause. United States v. Salter, 2023 U.S. Dist. LEXIS 119269 (M.D. Ala. June 7, 2023), adopted, 2023 U.S. Dist. LEXIS 115746 (M.D. Ala. July 6, 2023).
Plaintiff was 8½ months pregnant when her place was raided under a warrant. She went into labor and delivered. She has PTSD. “Penate sued the City of Worcester and several officers involved in the entry, claiming that the officers violated her constitutional rights and committed several torts, for which the City was also liable. The district court granted summary judgment for the City and the individual defendants, reasoning that none of the officers violated Penate’s constitutional rights and that even if they did, they are entitled to qualified immunity. As we will explain, we agree that the individual defendants are entitled to qualified immunity and that neither they nor the City are liable for the other torts alleged.” Penate v. Sullivan, 2023 U.S. App. LEXIS 17510 (1st Cir. July 11, 2023).*
The challenged jury instruction in this § 1983 case accurately stated the law about arrests at the threshold. Marvin v. Holcomb, 2023 U.S. App. LEXIS 17514 (7th Cir. July 11, 2023).*
Plaintiff’s Facebook posts of her shooting guns on her property supported the use of flashbang devices when her house was subjected to a drug raid by the SWAT team. Davenport v. City of Little Rock, 2023 U.S. Dist. LEXIS 119102 (E.D. Ark. July 11, 2023).
Defendant was handcuffed and talked to in aggressive and accusatory tones, and it wasn’t justified by the facts. It turned out there was a gun in the car, but he was outside of the car, and the police didn’t know that before it all went down. United States v. In, 2023 U.S. Dist. LEXIS 118613 (D. Nev. July 11, 2023).*
The first time CI was adequately corroborated by other information the police already knew. United States v. Watkins, 2023 U.S. Dist. LEXIS 118636 (W.D. Okla. July 11, 2023).*
Defendant was arrested away from his home so the police could more safely search it. Then, “Defendant admitted to a smorgasbord of crimes during a post-arrest interview with officers.” United States v. Moriarity, 2023 U.S. Dist. LEXIS 118632 (N.D. Ind. July 10, 2023).*
Defendant was arrested in Mexico and subjected to searches and interrogation which he claimed amounted to torture. Relying on the United Nations Convention Against Torture, he contended it shocked the conscience. There is no authority for the CAT to apply to excluding criminal evidence. In addition, there was no joint venture with the U.S. Defendant was let loose at the border, and he walked into the U.S. and was arrested. United States v. Pierson, 2023 U.S. App. LEXIS 17446 (8th Cir. July 11, 2023).
Defendant was probably faking sleeping in a car the police thought had been abandoned; it had been parked there for a couple of weeks. The side windows were heavily tinted, and the officer looked through the windshield and saw blunts and the outline of a gun in defendant’s sweat pants. There was reasonable suspicion to get him out of the car. Commonwealth v. Green, 2023 PA Super 121, 2023 Pa. Super. LEXIS 301 (July 11, 2023).*
The trial court erroneously suppressed. “We feel the trial court’s ruling was clearly erroneous. There was probable cause for the detention and subsequent arrest of the defendant. The call to 911 indicated the defendant was acting unruly as he had done on a previous occasion and claimed that he had a weapon. Upon approaching defendant, the officers experienced the defendant becoming defensive and combative and therefore sought to handcuff him for protective reasons. At this point the defendant fought off the handcuffs and bit one of the officers. A search incident to defendant’s arrest revealed the gun.” State v. Falkins, 2023 La. App. LEXIS 1146 (La. App. 4 Cir. June 28, 2023).*
Posted inDue process, Probable cause, Reasonable suspicion|Comments Off on CA8: Even if def’s Mexican confession was obtained by alleged torture, the UN Convention Against Torture doesn’t have a suppression remedy
“But in any event, even where Fourth Amendment violations have occurred—which, the Court takes pains to restate, is not the case here—a dismissal of an indictment is generally not the appropriate remedy. United States v. Morrison, 449 U.S. 361, 365-66, 101 S. Ct. 665, 66 L. Ed. 2d 564 (1981) (‘[W]e have not suggested that searches and seizures contrary to the Fourth Amendment warrant dismissal of the indictment. The remedy in the criminal proceedings is limited to denying the prosecution the fruits of its transgression.’). The Court thus declines to dismiss the indictment on these asserted grounds.” United States v. Gedeon, 2023 U.S. Dist. LEXIS 118234 (E.D. Pa. July 10, 2023).
The bulge in defendant’s clothing suggested a gun, and that justified a patdown. State v. Garcia, 2023-Ohio-2346 (5th Dist. July 5, 2023).*
The search warrant based on the dog sniff of defendant’s apartment door was previously upheld. Defendant’s claim that it led to another search is not suppressible. United States v. Peck, 2023 U.S. Dist. LEXIS 117859 (D.Neb. June 20, 2023) (R&R).*
“[D]efendant had reasonable expectation of privacy in data stored on his laptop’s hard drive, whether data was electronically stored on his hard drive or government’s copy of hard drive made with defendant’s consent. Defendant’s reasonable expectation of privacy was not eliminated by government’s copying of hard drive because no data was exposed prior to his withdrawal of consent. Supreme Court held that, under circumstances of defendant’s consent, reasonable person would not think that government could examine data on copy after withdrawal of consent when no examination occurred prior to withdrawal. Government’s examination of data after defendant withdrew consent was search, which was unreasonable because government lacked any authority to conduct search, by warrant or exception to warrant requirement.” State v. McDonnell, 2023 Md. LEXIS 301 (July 7, 2023). See Reason: Withdrawal of Consent to Search Computers Also Blocks Searches of Digital Copies, Court Holds by Orin Kerr.
Defendant was driving what appeared to be a fleet commercial truck for a cable installer, but everything seemed off for winter weather. “As noted above, several details indicated to Trooper Mills that the truck was likely a staged commercial vehicle. The totality of the circumstances support Trooper Mills’s reasonable suspicion of criminal activity because he was ‘able to point to specific and articulable facts’ from the start of the stop to support a ‘rational inference[]’ of narcotic trafficking. Terry, 392 U.S. at 21. Thus, Trooper Mills’s EPIC search was appropriate, as was his question to Grajeda-Sanchez about Grajeda-Sanchez’s job and his decision to look underneath the truck bed. Accordingly, the traffic stop was lawfully extended.” United States v. Grajeda-Sanchez, 2023 U.S. Dist. LEXIS 117502 (D. Minn. July 10, 2023).*
Where the search warrant sought clothing worn during a shooting, nexus was shown to where defendant lived. State v. Johnson, 2023 Del. Super. LEXIS 324 (July 7, 2023).
There was probable cause for plaintiff’s arrest for harassment of another person. In fact, he was convicted of it. Yoast v. Pottstown Borough, 2023 U.S. App. LEXIS 17264 (3d Cir. July 10, 2023).*
Prior to the shooting here, SCOTUS had never held that shooting at a recklessly driven vehicle evading arrest was excessive force. “And while it is true that the New York Police Department Patrol Guide directs officers to refrain from shooting into moving vehicles when the threat of deadly force stems from the vehicle alone, it was, at minimum, not clearly established that the Fourth Amendment includes such a requirement. See, e.g., Plumhoff v. Rickard, 572 U.S. 765, 776-77, 134 S. Ct. 2012, 188 L. Ed. 2d 1056 (2014) (finding no Fourth Amendment violation where police shot at fleeing suspect to end car chase).” Martinez v. Hasper, 2023 U.S. App. LEXIS 17287 (2d Cir. July 10, 2023).*
After Iowa permitted open carry, accosting defendant for carrying a firearm lacked reasonable suspicion. United States v. McMillion, 2023 U.S. Dist. LEXIS 117283 (S.D. Iowa June 30, 2023).
The search warrant for defendant’s cell phone permitted a search by use of biometric information but not getting the password. Defendant consented to providing the password. United States v. Hinson, 2023 U.S. Dist. LEXIS 117396 (N.D. Ohio July 7, 2023).*
Defendant’s inability to produce the rental agreement for the car he was driving raised questions of his authority to possess the car. That justified the 10 second delay in contacting the officer with the drug dog and then running the dog. United States v. Cates, 2023 U.S. App. LEXIS 17250 (10th Cir. July 7, 2023).*
Leaving the wrong search warrant at the scene of the search is not a ground to suppress. United States v. Major, 2023 U.S. Dist. LEXIS 116569 (E.D. La. July 7, 2023).
The CI had no track record, but his story was self-incriminating and against penal interest. It gave probable cause. United States v. Cortez-Gomez, 2023 U.S. Dist. LEXIS 116803 (N.D. Ill. July 7, 2023).*
The smell of marijuana coming from defendant’s car was reasonable suspicion to extend the stop. United States v. Strawther, 2023 U.S. Dist. LEXIS 116831 (D.S.D. July 5, 2023).*
On defendant’s Franks challenge, “I assume without deciding that Rodriguez-Cumba prevails on the government’s first two arguments. Nevertheless, I recommend finding the search warrant was supported by probable cause regardless of the supposed misrepresentations he identified.” United States v. Rodriguez-Cumba, 2023 U.S. Dist. LEXIS 117251 (D.P.R. July 7, 2023).*
WIRED: Why We Don’t Recommend Ring Cameras by Adrienne So (“They’re affordable and ubiquitous, but homeowners shouldn’t be able to act as vigilantes.”):
In the reasonable suspicion calculus, the officer’s experience has value. United States v. Douglas, 2023 U.S. App. LEXIS 17171 (D.C. Cir. July 7, 2023) (per curiam, but 2-1), Randolph, J., concurring:
“Small abandoned his legitimate expectation of privacy in the backpack. Although Small arguably demonstrated a subjective expectation of privacy by attempting to hide the backpack under his seat (though this act could also be viewed as an effort to physically abandon the backpack in the closed car), any subjective expectation was rendered objectively unreasonable when he explicitly disclaimed ownership by stating ‘this is not my backpack.’” United States v. Small, 2023 U.S. App. LEXIS 17117 (3d Cir. July 7, 2023).*
The state met its burden of showing exigency in a blood draw from an unconscious DWI suspect in the hospital. State v. Burris, 2023 N.C. App. LEXIS 393 (July 5, 2023).*
Cash found during an otherwise valid inventory was admissible. United States v. Carey, 2023 U.S. App. LEXIS 17122 (3d Cir. July 7, 2023).*
Plaintiffs’ admissions they were arrested for violating curfew in a BLM protest after the Floyd murder defeated their false arrest claims. Tinius v. Choi, 2023 U.S. App. LEXIS 17175 (D.C.Cir. July 7, 2023).*
Seeking to have defendant use his fingerprint to unlock his cell phone was not testimonial. The Second Circuit hasn’t ruled yet. “Nevertheless, the Court is persuaded by the weight of authority in other circuits, which holds that the compelled use of a defendant’s biometric features to unlock a phone does not amount to a testimonial communication, and therefore does not run afoul of the Fifth Amendment.” United States v. Eldarir, 2023 U.S. Dist. LEXIS 116126 (E.D.N.Y. July 6, 2023):
The warrant was issued by a U.S. Magistrate Judge, but it is reviewed under New York law which retained Aguilar/Spinelli, and it meets the test. People v. Mercado, 2023 NY Slip Op 23195, 2023 NYLJ LEXIS 1655, 2023 N.Y. Misc. LEXIS 3214 (Queens Co. July 3, 2023). (It just worked out that way here. Another state court may say that the warrant is reviewed under the Fourth Amendment and not state law.)
“Trial counsel’s advice to not pursue a motion to suppress based on Petitioner’s contorted view of the scope of consent, therefore, is best seen as strategic in nature.” He also doesn’t show he would have gone to trial instead. Nelson v. United States, 2023 U.S. Dist. LEXIS 115717 (D.N.M. July 6, 2023).*
Defendant doesn’t allege or show a reasonable expectation of privacy in the place searched under a warrant, even after the government challenged the lack of standing. Even if he had standing, the warrant was issued with probable cause. United States v. Bell, 2023 U.S. Dist. LEXIS 115843 (E.D. Wis. May 19, 2023),* adopted 2023 U.S. Dist. LEXIS 114748 (E.D. Wis. July 5, 2023).*
One statement was suppressed, and it was removed from the application for the warrant, and probable cause still remained. “Even if the benign snippet of suppressed information in the search warrant application somehow was necessary to establish probable cause, Leon’s good faith exception applies.” United States v. Green, 2023 U.S. Dist. LEXIS 116176 (M.D.Ga. July 6, 2023).*
A search warrant for a cell phone includes the SD card in it. United States v. Glatz, 2023 U.S. Dist. LEXIS 114963 (E.D. Tenn. July 5, 2023).
A jury question on probable cause to arrest remained, and that avoids qualified immunity for now. Johnson v. Barr, 2023 U.S. App. LEXIS 17019 (9th Cir. July 6, 2023).*
Defendant’s post-conviction claim that the warrant was based on three controlled buys that should have been challenged was speculative. State v. Miller, 2023-Ohio-2290, 2023 Ohio App. LEXIS 2304 (7th Dist. June 26, 2023).*
“Stewart, however, challenges these issues for the first time on appeal. Stewart did not file a motion to suppress the evidence, he made no objections to the introduction of the evidence at trial and he did not challenge the inclusion of the evidence in his post-trial motion. Thus, Stewart is procedurally barred from challenging these issues. Shinstock v. State, 220 So. 3d 967, 970 (Miss. 2017) (“‘The rule that failure to object’ at trial bars raising the issue on appeal ‘applies to Fourth Amendment claims as well.'” … Additionally, Stewart failed to ask this Court to consider a plain error analysis until his reply brief, after the State had already pointed out this issue and argued waiver.” Stewart v. State, 2023 Miss. LEXIS 184 (July 6, 2023).*
• Police departments cross-country are using drones in their daily operations. • New drones have the capability to break through glass, enter buildings, and open doors. • Only 15 states in the US require police to have search warrants to use drones.
Posted inDrones|Comments Off on Insider: Police use of high tech drones is on the rise, and regulations aren’t keeping up with them
Posted inSurveillance technology|Comments Off on Sacramento Bee: Sacramento Sheriff is sharing license plate reader data with anti-abortion states, records show
Defendant was arrested for first-degree aggravated manslaughter as a result of an accident after he injected himself with fentanyl-laced heroin. He was under arrest at the scene, but he wasn’t actually searched until he was in the hospital. The search at the hospital an hour and a half later was substantially contemporaneous with the arrest and was valid as a search incident. State v. Vanderee, 2023 N.J. Super. LEXIS 72 (July 5, 2023).
“Bell lacked a reasonable expectation of privacy in (1) the triplex generally, (2) the specific areas searched, and (3) the items the police seized from the second-floor unit. … Bell did not have a possessory or ownership interest in the unit; he was merely visiting his sister, and for only the third time. Indeed, his mail listed a different address. There is no evidence to suggest that he ever stayed overnight.” United States v. Bell, 2023 U.S. Dist. LEXIS 114748 (E.D. Wis. July 5, 2023).*
The premises searched was actually a duplex, but the officer presented information for the warrant that essentially included both sides because it was believed to be one residence. The warrant was not unparticular. United States v. Davidson, 2023 U.S. Dist. LEXIS 114965 (E.D.Mich. July 5, 2023).*
Appellant seeks to relitigate his motion to suppress affirmed on appeal by arguing that a new rule of constitutional law applied. Only it doesn’t. In re Sumlin, 2023 U.S. App. LEXIS 16966 (6th Cir. July 5, 2023).*
A police ride-along with a student led to a sexual assault § 1983 suit. “It is well established that sexual assault by a government official acting under color of law violates the Constitution. Cases from different circuits have relied on different constitutional provisions, but they have agreed on that bottom line, holding that sexual assault can violate the Fourteenth Amendment Equal Protection Clause as sex discrimination, the Fourth Amendment right ‘of the people to be secure in their persons,’ and the right to bodily integrity protected by the Fourteenth Amendment Due Process Clause.” “Before digging into the substantive due process jurisprudence, we acknowledge that the Fourth Amendment will often provide the proper avenue for litigating a claim of sexual assault by an official acting under color of law.” Hess v. Garcia, 2023 U.S. App. LEXIS 16894 (7th Cir. July 5, 2023). See Bloomberg: Officer Must Face Teen’s Claims of ‘Ride Along’ Sexual Assault
“[M]alicious prosecution claims under § 1983 are not the types of malicious prosecution tort claims that might abate under Kentucky law. Defendants’ motion to dismiss for lack of jurisdiction is accordingly denied.” Price v. Montgomery Cnty., 2023 U.S. App. LEXIS 16899 (6th Cir. July 5, 2023).*
A road rage incident with an off-duty law enforcement officer led to the officer getting charged with aggravated assault and child endangerment of his own child. Qualified immunity denied. “Under the facts as alleged in the complaint, Bradshaw violated Rosales’s constitutional right to be free from unreasonable seizures, and his egregious and unlawful conduct was obviously unconstitutional. Bradshaw is therefore not entitled to qualified immunity, and Rosales’s § 1983 claim against him may proceed.” Rosales v. Bradshaw, 2023 U.S. App. LEXIS 16886 (10th Cir. July 5, 2023).*
“The Commonwealth bears the burden of proving that a warrantless search fits under an exception to the warrant requirement of the Fourth Amendment. While the exceptions are many, mere probable cause to arrest is not one of them. Nor can a search be incident to an arrest when the arrest comes two months after the search. As such, we must reverse and remand for further proceedings.” “As we explain below, probable cause that an individual has contraband, without more, meets the standard for obtaining a warrant, not searching without one. We then conclude the record the Commonwealth developed below is insufficient to allow us to apply the right result, wrong reason doctrine and affirm on any other ground. Finally, we find that the good-faith exception to the exclusionary rule does not apply.” Parady v. Commonwealth, 2023 Va. App. LEXIS 428 (July 5, 2023):
Posted inArrest or entry on arrest|Comments Off on VA: “[U]nder the Fourth Amendment, probable cause of contraband is the standard to obtain a warrant, not the standard to search a person without one.”
The initial tip about defendant being a drug dealer was anonymous, but officers investigated to corroborate it. “Detectives went to the address associated with the phone number provided by the anonymous source, observed activity which they believed was consistent with the sale of narcotics, and conducted four trash pulls—from which they seized a substantial amount of drug refuse, including approximately thirty baggies with suspected narcotics residue (several of which were tested and revealed positive results for the presence of cocaine), multiple cut-up lottery tickets (which they knew from training and experience to be consistent with packaging for heroin and fentanyl), and bulk-sized bottles of Promethazine (intended for use by pharmacies to fill prescriptions, not for personal use).” That gave probable cause. United States v. Nelson, 2023 U.S. Dist. LEXIS 114505 (E.D. Mich. June 29, 2023).*
Overtinted windows justify the stop, and the smell of marijuana came from the car. Defendant was asked about smoking in the car, and he said “not recently.” In the backseat was marijuana and money. A search warrant for heroin was based on probable cause and was particular. United States v. Cabrera, 2023 U.S. Dist. LEXIS 113209 (S.D.N.Y. June 29, 2023).*
“Based on the totality of the circumstances as they existed at the time that Jones approached Patterson, Jones had a particularized and objective basis for suspecting that Patterson was violating Michigan law that prohibits carrying a concealed weapon without a license. Jones testified that he decided to approach Patterson after seeing him try to conceal what appeared to be a firearm in the left pocket of Patterson’s sweatshirt. He stated that he observed an L-shaped object in the left pocket that, in his experience, was consistent with the size and shape of a firearm. … Jones and Patterson made eye contact as Patterson exited the gas station, after which Patterson’s body movement changed.” And he “bladed” away. United States v. Patterson, 2023 U.S. Dist. LEXIS 113797 (E.D. Mich. June 30, 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.
