The protective sweep of defendant’s place wasn’t unreasonable. There was a history of domestic violence there, and there was a potential shooting on the premises. When officers knocked, the lights went out. While people don’t have to answer the door, they could consider that with all the facts. United States v. Shaka, 2024 U.S. Dist. LEXIS 239224 (D. Minn. Dec. 9, 2024).*
“Upon our in camera review of the search warrant materials, including the search warrant application, the police officer’s supporting affidavit, and the testimony of both the officer and the confidential informant before the warrant-issuing court, we find that there was probable cause to issue the warrant.” People v. Holmes, 2025 NY Slip Op 00730 (1st Dept. Feb. 6, 2025).*
Officers had an order of protection to serve on plaintiff, and he refused to come out of the house, so they pulled him out and then charged him with obstruction. Qualified immunity denied. McKenna v. Erickson, 2025 U.S. App. LEXIS 2708 (4th Cir. Feb. 6, 2025).*
Defense counsel wasn’t ineffective for not objecting to the CSLI records which were coming in in any event as business records. He’d objected before trial to the search and lost, and that was argued on direct appeal and lost. State v. Goynes, 318 Neb. 413 (Feb. 7, 2025).
Any error in cell phone location information in the affidavit wasn’t shown to be material or reckless. Defendant was seen on video in a robbery with the cell phone. That puts one at the scene. United States v. Jackson, 2025 U.S. App. LEXIS 2529 (6th Cir. Feb. 3, 2025).*
“Counsel’s failure to challenge the search warrant of the defendant’s backpack did not constitute ineffective assistance of counsel; the warrant was supported by probable cause.” People v. Sobers, 2025 NY Slip Op 00679 (2d Dept. Feb. 5, 2025).*
The traffic stop was valid, and an NCIC search produced a warrant that extended the stop. United States v. Clem, 2025 U.S. Dist. LEXIS 20654 (E.D. Ky. Jan. 26, 2025).*
Search incident of a car for a DUI is permissible in Georgia. Morris v. State, 2025 Ga. App. LEXIS 41 (Feb. 6, 2025).
Misstating the implied consent law to defendant made defendant’s consent invalid. State v. Johnson, 2025 Haw. App. LEXIS 37 (Jan. 30, 2025) (unpublished).*
Petitioner’s Fourth Amendment ineffective assistance claim fails because he can’t show that arguing the claim differently would have produced suppression of evidence. He testified he was disappointed defense counsel at trial didn’t like his arguments. Shanklin v. State, 2025 Tenn. Crim. App. LEXIS 69 (Feb. 4, 2025).*
“Hamber concedes that Officer Ware had probable cause supporting the initial stop, and we have already determined that the initial stop did not end until after Hamber consented to the pat-down search. Thus, Hamber’s pretext argument fails.” United States v. Hamber, 2025 U.S. App. LEXIS 2541 (8th Cir. Feb. 5, 2025).*
Officers were in defendant’s house investigating a gas leak. A kitchen cabinet had a chain and lock on it, and the police while in the house manipulated it and shined a flashlight to see what was inside. This was an unreasonable search. People v. Hagestedt, 2025 IL 130286, 2025 Ill. LEXIS 185 (Feb. 6, 2025):
The drug dog officer facilitated the drug-detection dog’s entry into Pham’s vehicle by leaving the door open and partially closing and reopening it to allow the dog to enter. That constituted a search under the Fourth Amendment, following Felders v. Malcolm from the Tenth Circuit. That search was conducted without probable cause, and the officers had no indication defendant was involved in criminal activity or that his vehicle contained contraband beyond the traffic violation. The court recognized that instinctive action from the dog likely would not constitute a search, but that is not this. People v. Dinh Pham, 2025 CO 4, 2025 Colo. LEXIS 89 (Feb. 3, 2025):
Impeaching defendant’s trial testimony about the search of his property using his proffer agreement was prejudicial, but it was harmless on this record. They could have cross-examined without it. United States v. Grogan, 2025 U.S. App. LEXIS 2354 (6th Cir. Feb. 3, 2025). [In my experience, any testimony about the conduct of the search isn’t really relevant, unless you can show evidence was planted, and it opens the door for the prosecution to go into things that sure won’t help.]
Probable cause was shown for the warrant here even without defendant’s statement. United States v. Campbell, 2025 U.S. Dist. LEXIS 19358 (N.D. Okla. Feb. 4, 2025).*
This case involved an anti-doping allegation about the 2020 Tokyo Olympics. The search warrant for defendant’s phone was sufficiently particular as to the crime under investigation to guide the search. United States v. Barrett, 2025 U.S. Dist. LEXIS 18935 (S.D.N.Y. Feb. 3, 2025).*
The trial court’s order on impoundment and inventory is reversed for more findings. The impoundment might have been unnecessary because defendant wanted to have the vehicle towed. The unwritten inventory is too nebulous to understand, even with the discussion on bodycam. Huertas v. State, 2025 Ga. App. LEXIS 31 (Feb. 3, 2025).*
“The Fourth Amendment, not ICRA, applies here. For one thing, BIA officers are federal officers empowered by federal statute to act. For another, even if Dillon and Flute subjectively believed they were enforcing tribal law—which the Court is convinced of—they still had independent federal authority to arrest Bromwich for possessing marijuana. This is true despite South Dakota condoning medical-marijuana, and federal funding limitations placed on the Department of Justice to discourage enforcing the federal prohibition. Cannabis remains federally prohibited as a Schedule I drug. The federal officers were exercising their federal powers when interacting with Bromwich. The Fourth Amendment is the instrument to analyze Bromwich’s motion. But no matter, ICRA adopts Fourth Amendment precedent. So the distinction has no difference.” United States v. Bromwich, 2024 U.S. Dist. LEXIS 238961 (D.S.D. Dec. 20, 2024).
On appeal from the R&R:
Even if Dillon and Flute were acting under tribal law, “[t]he Supreme Court has recognized that tribal law enforcement authorities possess ‘traditional and undisputed power to exclude persons whom they deem to be undesirable from tribal lands,’ and therefore have ‘the power to restrain those who disturb public order on the reservation, and if necessary to eject them.'” … “Because such power ‘would be meaningless if tribal police were not empowered to investigate [the undesirable conduct], tribal police must have such power.'” … Therefore, Dillon and Flute did not violate Bromwich’s Fourth Amendment right to be free from unreasonable seizure because they had the authority to investigate Bromwich’s drug possession and determine whether to eject him from the reservation.
United States v. Bromwich, 2025 U.S. Dist. LEXIS 17753 (D.S.D. Jan. 29, 2025). And, even if there wasn’t probable cause for defendant’s arrest, his active resistance was an independent crime that justified it.
Posted inArrest or entry on arrest|Comments Off on D.S.D.: Tribal officers governed by 4A and Indian Civil Rights Act
Knock-and-announce failure doesn’t lead to suppression. United States v. Benlevi, 2025 U.S. App. LEXIS 2452 (9th Cir. Feb. 4, 2025).
Police were called to a motel where a vehicle was illegally parked in a handicapped zone for an hour allegedly dealing drugs to hotel occupants. The police approach of the car was valid under Terry, and drugs were seen in plain view. Johnson v. State, 2025 Miss. App. LEXIS 48 (Feb. 4, 2025).*
Petitioner had a full and fair opportunity to litigate his Fourth Amendment claims in state court, so he can’t bring them in habeas. CoA denied. Butler v. Campbell, 2025 U.S. App. LEXIS 2458 (6th Cir. Feb. 3, 2025).*
The district court had no jurisdiction over petitioner’s Rule 60 motion for newly discovered evidence about his search, so CoA denied. Price v. United States, 2025 U.S. App. LEXIS 2460 (6th Cir. Feb. 3, 2025).*
Defendant’s general objections to the R&R on his search claims don’t attempt to show the alleged errors in the USMJ’s reasoning and just rehashed the original arguments. Overruled, and adopted. United States v. Shaka, 2025 U.S. Dist. LEXIS 19267 (D. Minn. Feb. 4, 2025).*
The government carried its burden of consent. “The dispositive facts that require denial of the defendant’s motion to suppress are that Mrs. Ramos gave the NYPD written and verbal consent to search her apartment, and there is no evidence of coercion by the police that would render her consent involuntary. … There is no dispute that Mrs. Ramos signed a Consent Form. See GX1; Tr. at 123:9 (Mrs. Ramos: ‘I signed it.’). It states that she ‘voluntarily consent[ed] to a complete search’ of her apartment. GX1. The Consent Form that Mrs. Ramos indisputably signed also advised her of her rights to ‘refuse’ and to ‘revoke’ her consent, in whole or in part, at any time. GX1. Further, at the hearing, the defendant’s own witness, Tiffany Mercado, testified that the police ‘asked’ for and received Mrs. Ramos’ verbal consent to search the closet where they found the rifle and ammunition the defense seeks to suppress.” United States v. Ramos, 2025 U.S. Dist. LEXIS 18056 (S.D.N.Y. Jan. 31, 2025).*
A tracking order to install a tracker on a package left outdoors expected to be moved again permitted entry into the backyard of an apartment house to place it. Also, there was no reasonable expectation of privacy in that backyard. United States v. Bell, 2025 U.S. Dist. LEXIS 19151 (M.D. Pa. Feb. 4, 2025).*
The officer’s briefly touching the vehicle’s exterior to redirect the canine’s focus did not constitute a search. The dog’s certification and training were sufficient to establish its reliability, absent conflicting evidence from the defendant. This traffic stop was not unconstitutionally extended because the canine sniff did not add time to the stop. The dog was already present before all occupants had exited the vehicle. State v. Bond, 2025-Ohio-360 (5th Dist. Feb. 3, 2025).
This murder search warrant was not stale. It was based on information developed in December 2022 corroborated by DNA and other evidence in June 2023. State v. Barnes, 2025 Del. Super. LEXIS 37 (Jan. 29, 2025).*
Defendant’s request for a Franks hearing is denied. Even with omissions, there remained probable cause. United States v. Witmer, 2025 U.S. Dist. LEXIS 17909 (D. Mont. Jan. 31, 2025).*
The ping of defendant’s cell phone to find him when a 13-year-old girl went missing was based on exigency under state statute. Brooks v. State, 2025 Ind. App. LEXIS 19 (Jan. 31, 2025).
All the factors supported reasonable suspicion: CI tip, flight, high-crime area, other evasive conduct. United States v. Rodgers, 2025 U.S. Dist. LEXIS 17258 (W.D. La. Jan. 22, 2025).*
While recognizing that staleness in child pornography cases can have an nearly unlimited lifespan, “the Court is mindful that there is some limit on the bounds of evidence not becoming stale, even in the child pornography context, it finds this case does not cross the line.” There was probable cause and the good faith exception applies. United States v. Scherer, 2025 U.S. Dist. LEXIS 17475 (N.D. Ohio Jan. 31, 2025).*
There is no reasonable expectation of privacy in an LPN from being checked. United States v. Winters, 2025 U.S. Dist. LEXIS 17401 (N.D. Iowa Jan. 31, 2025).*
Defendant satisfied his burden showing that he received ineffective assistance of counsel in defense counsel’s failure to move to suppress his cell phone search. People v. Conley, 2025 NY Slip Op 00597 (4th Dept. Jan. 31, 2025).*
The order suppressing the search warrant for lack of probable cause is affirmed. The trial court faulted the chain of custody of the result of the trash search. People v. Scullin, 2025 NY Slip Op 00559 (4th Dept. Jan. 31, 2025).*
Defendant’s presence in a room with drugs two years before the search in question didn’t prove his knowledge here. People v. Henderson, 2025 NY Slip Op 00537 (4th Dept. Jan. 31, 2025).*
The totality of the circumstances, including the nature of the domestic violence call, appellant’s armed presence near the scene, his rapid movement towards the officers while armed, and the short timeframe, made the officers’ use of deadly force objectively reasonable from the perspective of a reasonable officer. Officers need not wait for a suspect to point a gun before using deadly force if they reasonably perceive a threat of severe harm. Holland v. Cheatham Cty., 2025 Tenn. App. LEXIS 28 (Jan. 28, 2025).
Petitioner’s successor petition on ineffective assistance of counsel is denied. That’s not proper grounds. In re Davis, 2025 U.S. App. LEXIS 2197 (11th Cir. Jan. 30, 2025).*
“Here, it is uncontroverted that Mitchell abandoned his bicycle, together with the attached brown satchel and its contents, before Deputy Sams was able to catch and physically seize him. … Furthermore, although Mitchell later admitted to deputies his ownership of the items in his jacket, he conspicuously refused to speak up or answer any questions about the satchel. … In other words, when offered the opportunity to reassert his ownership in the previously abandoned brown satchel and its contents, Mitchell remained mum.” United States v. Mitchell, 2025 U.S. Dist. LEXIS 16316 (W.D. La. Jan. 13, 2025),* adopted, 2025 U.S. Dist. LEXIS 15339 (W.D. La. Jan. 28, 2025).*
Defendant voluntarily disclosed his cell phone passcode to the officers when the officer said he’d get a warrant for it. State v. Harris, 2025 Kan. LEXIS 5 (Jan. 31, 2025):
Posted inCell phones, Consent, Voluntariness|Comments Off on KS: Def voluntarily disclosed his cell phone passcode to the officers when the officer said he’d get a warrant
“The record is devoid of evidence to support the conclusion that Detective Uhrig’s decision to impound Smith’s car was reasonable under the circumstances.” The inventory depending on the legality of the impoundment. Reversed. State v. Smith, 2025 Ida. LEXIS 8 (Jan. 30, 2025).
The affidavit for search warrant for defendant’s phone actually lacked probable cause, but the trial court found the good faith exception applied. On appeal, that finding was not against the preponderance of the evidence. Vasquez v. State, 2025 Ark. App. 65 (Feb. 5, 2025).* (The conviction was reversed on other grounds.)
The good-faith exception to the exclusionary rule applies, and thus evidence obtained from Carter’s real-time cell site location information should not be suppressed, because law enforcement officers acted in objectively reasonable reliance on the federal Stored Communications Act, which explicitly permitted this. State v. Carter, 2025 S.C. LEXIS 14 (Jan. 29, 2025).*
Posted inGood faith exception, Inventory|Comments Off on ID: State completely failed to support justification for inventory
While the officer in charge of the DL roadblock (highway safety) essentially admitted it was for general crime control (see Edmund v. City of Indianapolis), the court goes with the DUI arrest being valid. The officer “was the most inexperienced law enforcement officer for the Town of Puckett. That’s not his fault. That’s just the nature of what it is. He started in January of 2023. He’s a part-time worker. He does other work primarily. This is a part-time job for him.” Kendrick v. State, 2025 Miss. LEXIS 23 (Jan. 30, 2025). This is reminiscent of the Barney Fife exception to the Fourth Amendment. Update: techdirt: Mississippi’s Top Court Says Rights Violations Are OK If Cops Don’t Know How To Do Their Jobs by Tim Cushing
On a turn signal violation: “… the question is not whether Moore was affected by Defendant’s turn; the question is whether Moore had probable cause to believe that he may have been affected. Moore was the only vehicle traveling in the area. He was traveling directly behind Defendant. Moore did not need to turn his vehicle or stop abruptly — or stop at all — due to Defendant’s failure to use a turn signal.” United States v. Bailey, 2025 U.S. Dist. LEXIS 15485 (N.D. W.Va. Jan. 29, 2025).*
The body cam video shows defendant consented to the search of his vehicle and didn’t seek to limit it in any way. State v. Warren, 2025-Ohio-256 (7th Dist. Jan. 28, 2025).*
No 2254 CoA for defendant’s Fourth Amendment litigated in state court on plain error review. Youngblood v. Corrigan, 2025 U.S. App. LEXIS 2076 (6th Cir. Jan. 29, 2025).*
Posted inIssue preclusion, Probable cause, Roadblocks|Comments Off on MS: Admitted “general crime control” roadblock still upheld based on part-time officer’s inexperience
The initial detention and exterior inspection of the parcel sent to defendant did not implicate his Fourth Amendment rights because it occurred within the guaranteed delivery window. He had no reasonable expectation of privacy in the exterior of the parcel given to a mail carrier. His only possessory interest was in the timely delivery of the parcel, which was not infringed during the initial detention. Then, officers obtained a search warrant and had reasonable suspicion to further detain the parcel after discovering methamphetamine within the delivery window. United States v. Ali-White, 2025 U.S. App. LEXIS 2112 (3d Cir. Jan. 30, 2025).*
The affirmation of counsel doesn’t satisfy the Second Circuit’s rule of a standing affidavit from the defendant. United States v. Rivera-Valentin, 2025 U.S. Dist. LEXIS 16236 (W.D.N.Y. Jan. 7, 2025),* adopted, 2025 U.S. Dist. LEXIS 15131 (W.D. N.Y. Jan. 28, 2025).*
The search of defendant’s car was justified by the smell of marijuana and the passenger’s consent to look for his keys. State v. Falcon, 33 Neb. App. 331 (Jan. 28, 2025).*
State prosecutors aren’t necessarily obliged to give over information on federal officers present at a state search considering they have no control over them and their testimony may be hard fought via Touhy letters and they may have nothing additional to add. People v. Adams, 2025 NY Slip Op 25019, 2025 N.Y. Misc. LEXIS 409 (Erie Co. Jan. 28, 2025).
Where a motion to suppress would not have succeeded, defense counsel can be ineffective for not moving to suppress. McGrier v. United States, 2024 U.S. Dist. LEXIS 238619 (S.D. W.Va. Dec. 17, 2024),* adopted, 2025 U.S. Dist. LEXIS 13915 (S.D. W.Va. Jan. 27, 2025).*
Defense counsel wasn’t ineffective on his parole search question. “Fortson cannot establish either prong of the Strickland standard because had prior counsel made this argument at the hearing, it would have failed.” United States v. Fortson, 2025 U.S. Dist. LEXIS 15520 (N.D. Ohio Jan. 29, 2025).*
Posted inIneffective assistance, Motion to suppress|Comments Off on NY Erie Co.: State prosecutors have no control over federal officers involved in state search for discovery purposes
Where the trial court denied the pretrial motion to suppress, cross-examination of the officer about the legality of the search was properly denied on objection by the state as potentially misleading to the jury. Damon v. State, 2025 Ark. App. 50, 2025 Ark. App. LEXIS 59 (Jan. 29, 2025).
Informant hearsay was extensively corroborated, so plaintiff’s suit against the search with the warrant fails. Annappareddy v. United States, 2025 U.S. App. LEXIS 1863 (4th Cir. Jan. 28, 2025).*
Ancient Roman statue was seized from a NYC art gallery by the Manhattan DA’s office getting a warrant for its return to Italy. Italy is immune, and the DA gets qualified immunity. The gallery bought it for $150,000. Safani Gallery, Inc. v. Italian Republic, 2025 U.S. Dist. LEXIS 14665 (S.D.N.Y. Jan. 28, 2025).*
Defendant shows no possessory interest in a gun seized from a car he was a passenger in and has no standing. United States v. Webber, 2025 U.S. Dist. LEXIS 14706 (W.D. Va. Jan. 27, 2025).*
Putting defendant’s cell phone into airplane mode wasn’t a search. The name “Red” was seen on the screen. There was independent probable cause for the cell phone warrant. United States v. Hudson, 2025 U.S. Dist. LEXIS 14952 (E.D. Mo. Jan. 10, 2025).
This was a search warrant for documentary evidence not mentioning firearms, but the police came upon firearms subject to plain view and could seize them. United States v. King, 2025 U.S. Dist. LEXIS 15070 (E.D.N.C. Jan. 27, 2025).*
“‘It is well established that a police seizure and inventory is not dependent for its validity upon the absolute necessity for the police to take charge of property to preserve it.’” Defense counsel wasn’t ineffective for not challenging the inventory because it was valid. Fowler v. State, 2025 Ga. App. LEXIS 20 (Jan. 28, 2025).*
"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.
