That searching officers didn’t leave behind Attachment B to the warrant after the search didn’t void the search. United States v. Whaley, 2024 U.S. App. LEXIS 16819 (2d Cir. July 10, 2024).
Collective knowledge here fails: “Based on the evidence adduced at the hearing, it is manifest that the vertical knowledge doctrine was not established here. Although it would be naive to ignore the fact that law enforcement agencies work closely together in executing arrests such as this one, the Government still has the burden to detail facts connecting the Inspection Service and the PRPB—something that was not done here. Consequently, to uphold the vital constitutional protections that the Fourth Amendment affords persons in Defendants’ situation, it is the Government alone which must bear the adverse consequences of its choice to rely on a witness with limited personal knowledge surrounding the details of the case.” United States v. Piñeiro-Castro, 2024 U.S. Dist. LEXIS 121461 (D.P.R. July 10, 2024).*
Plaintiff was a Joliet police officer. A search warrant was issued for her phone, and she was concerned there were intimate photos of her. The city and officers get qualified immunity for the search itself, but she states a state law claim for intrusion on seclusion from the searching officers sharing the photos. Socha v. City of Joliet, 2024 U.S. App. LEXIS 16858 (7th Cir. July 10, 2024).
Defendant’s guilty plea waived his Fourth Amendment claim, so it can’t be brought via 2255. United States v. Overla, 2024 U.S. Dist. LEXIS 121325 (W.D. Mich. July 10, 2024).*
The triggering condition of this anticipatory warrant was satisfied. Guilt or innocence isn’t established by that. United States v. Montanez, 2024 U.S. Dist. LEXIS 121294 (E.D.N.Y. July 10, 2024).*
Applying a balancing test, the court concludes that the exclusionary rule should not apply in a civil service hearing. (However, the punishment for the offense of allegedly drinking on the job based on a BAC test of .03 was excessive.) Crayton v. Sewerage & Water Board of New Orleans, 2024 La. App. LEXIS 1099 (La. App. 4 Cir. July 9, 2024).
Petitioner seeks to avoid application of Stone by (1) challenging the adequacy of the procedures used to examine this claim …, (2) asserting that alleged inadequacies in the state court proceedings on this claim mean that Stone does not apply …, and (3) asserting that Stone is no longer good law due to the AEDPA …. However, the Court finds these arguments unpersuasive, as (1) the record demonstrates that the state court proceedings regarding Petitioner’s Fourth Amendment claim were not a sham; (2) Petitioner’s underlying state court proceedings on his Fourth Amendment claim were at least as thorough as those in Good, and (3) the Sixth Circuit has applied Stone after passage of the AEDPA. … Accordingly, Stone prohibits the Court from addressing the merits of Petitioner’s Fourth Amendment claim, and Petitioner is not entitled to relief under § 2254 for this claim.” Roberson v. Eller, 2024 U.S. Dist. LEXIS 121126 (E.D. Tenn. July 10, 2024).*
In a domestic terrorism investigation, USMJs have the authority to issue search warrants outside their court’s jurisdiction. Defendant disputes that this investigation was not that, but it’s close enough. Even if the officers were mistaken, the court won’t suppress an otherwise valid warrant for this mistake. United States v. Morgan, 2024 U.S. Dist. LEXIS 120864 (W.D. Wis. June 5, 2024), adopted, 2024 U.S. Dist. LEXIS 119580 (W.D. Wis. July 9, 2024).
Defense counsel didn’t raise a Bond issue on lifting a suitcase to see how heavy it was, and this wasn’t ineffective assistance of counsel. “Defense Counsel either had not thought of this theory at the time, or having thought of it, had decided not to pursue it. As the record shows Defense Counsel’s conduct was reasonable at the time, the Court rejects Mr. Fernandez’s contrary, distorted-by-hindsight, reasoning.” Bond involved squeezing the luggage, not lifting it, and that’s a difference. Fernandez v. United States, 2024 U.S. Dist. LEXIS 121384 (D.N.M. July 10, 2024).*
On a motion to reconsider, there was ample probable cause from the historical facts to justify the search. United States v. Reyes-Valdez, 2024 U.S. Dist. LEXIS 120725 (E.D. Pa. July 10, 2024).*
While Colorado sheriffs have civil arrest powers, an agreement with CBP to enforce immigration law under 8 U.S.C. § 1357(g) violated state law. Nash v. Mikesell, 2024 COA 68, 2024 Colo. App. LEXIS 813 (July 3, 2024).
In a chase the car wrecked. As officers tried to get the driver out, gunfire was exchanged. A police dog was killed and his handler hit. Plaintiff was the passenger, and he was also shot by officers shooting at the driver. Syllabus: “The panel held that under clearly established Fourth Amendment law, Cuevas was seized. It was not clearly established, however, that the force the officers used was excessive. None of Cuevas’s cited cases clearly establish that officers violated her rights when they shot her while defensively returning fire during an active shooting. Nor was it obvious that the officers could not return fire after Castro killed their police dog and shot an officer. In excessive-force cases where police officers face a threat, the obviousness principle will rarely—if ever—be available as an end-run to the requirement that law must be clearly established.” Cuevas v. City of Tulare, 2024 U.S. App. LEXIS 16827 (9th Cir. July 10, 2024).*
Under Franks, an affidavit for a search warrant does not have to negate a possible affirmative defense. United States v. Pascoe, 2024 U.S. Dist. LEXIS 119992 (W.D. Ky. July 9, 2024).
There was probable cause for defendant’s arrest for DUI from having run off the road, smelling of alcohol, and other apparent factors. State v. Davis, 2024 MT 145, 2024 Mont. LEXIS 747 (July 9, 2024).*
Defense counsel filed a Brady motion over discrepancies in the search warrant affidavit, and additional discovery was provided by the government. A motion was filed but never ruled on before defendant pled guilty and waived it. Defendant is incorrect that defense counsel wasn’t effective for not filing such a motion. United States v. Steen, 2024 U.S. Dist. LEXIS 120285 (D. Mont. July 8, 2024).*
There is no reasonable expectation of privacy in one’s Google location data. It’s willingly shared with Google. United States v. Chatrie, 2024 U.S. App. LEXIS 16692 (4th Cir. July 9, 2024) (2-1):
The search warrant could seek to seize documents tending to show defendant’s control of the premises [indicia of ownership or control] under the Fourth Amendment. United States v. Moore, 2024 U.S. Dist. LEXIS 119486 (S.D. Ohio July 2, 2024).
There was probable cause for plaintiff’s stop and arrest, and that defeats his malicious prosecution action, despite the state case being nolle prossed. Also, he didn’t show the nolle pros was for reasons of innocence. Esco v. City of Chi., 2024 U.S. App. LEXIS 16677 (7th Cir. July 9, 2024).*
Defendant’s claim against forfeiture of all his electronics after a child porn raid was better addressed to Congress. United States v. Sanders, 2024 U.S. App. LEXIS 16685 (4th Cir. July 9, 2024).*
“We are also not impressed by Sanders’s appellate contention that the facts in the Affidavit were so ‘stale’ as to negate probable cause.” Nine months. “Here, the Affidavit conveyed the same critical information to the magistrate judge — the person who deliberately accessed the pornographic material on the Hurt Meh website probably had a sexual interest in children and was therefore likely to be a collector of child pornography. And the evidence of such activity would be recoverable for long periods of time, even after the pornographic material had been deleted from the computer.” “And we have recognized that the ‘staleness inquiry is unique in [the] child pornography context.’ See Bosyk, 933 F.3d at 330. That is — due to (1) the tendency of individuals who intentionally access to collect child pornography, and (2) the material’s electronic nature causing evidence of collection to be recoverable long after it is deleted — search warrants can reasonably be sustained ‘months, and even years, after the events that gave rise to probable cause.’ Id. at 331 (ruling that search warrant issued five months after ‘click’ was valid).” United States v. Sanders, 2024 U.S. App. LEXIS 16679 (4th Cir. July 9, 2024). [No case has ever found a CP warrant stale that I could find.]
“Here, the district court concluded that Defendants were entitled to qualified immunity on all of Garcia’s claims because Garcia had not shown a violation of his constitutional rights. We need not address that issue because even if Garcia could show a constitutional violation, his claim would still fail because he has not shown that ‘it was clearly established that the Fourth Amendment prohibited the officer[s’] conduct in the situation [they] confronted.’ See Mullenix v. Luna, 577 U.S. 7, 13 (2015).” Garcia v. Bermea, 2024 U.S. App. LEXIS 16571 (5th Cir. July 8, 2024).*
Posted inProbable cause, Qualified immunity, Staleness|Comments Off on CA4: PC was shown def was likely a collector of CP so nine-month-old information wasn’t stale
Defendant had no standing to contest the arrest of another person that led to his arrest under either the Fourth Amendment or the state constitution. Zuniga v. State, 2024 Ind. App. LEXIS 196 (July 8, 2024).
“Next, Windham says that he asked his trial counsel to file a Fourth Amendment suppression motion, but his trial counsel did not do so. To succeed on this argument, Windham needed to ‘prove that his Fourth Amendment claim is meritorious and that there is a reasonable probability that [plea decision] would have been different.’ Windham has not identified any alleged Fourth Amendment violation, so Windham has not met his burden.” United States v. Windham, 2024 U.S. Dist. LEXIS 119596 (N.D. Ohio July 9, 2024).
There was no Fourth Amendment violation here, let alone an egregious one. Hernandez-Quintero v. Garland, 2024 U.S. App. LEXIS 16669 (9th Cir. July 9, 2024).*
Defendant was entitled to discovery of body camera footage of how a search was conducted. United States v. Moore, 2024 U.S. Dist. LEXIS 119486 (S.D. Ohio July 2, 2024).
The fact a Sixth Circuit judge dissented on a similar issue doesn’t show that defendant’s IAC issue has merit. Moralez v. United States, 2024 U.S. Dist. LEXIS 119022 (W.D. Ky. July 8, 2024).*
Moore’s argument is that Officer Brandon Connley’s affidavit in support of his request for that warrant could not support a probable cause finding because it did not mention the other suspect police also had been surveilling as part of its investigation into Moore’s alleged drug trafficking activities. But as explained below, this challenge fails on two independent grounds: (1) Moore has forfeited this argument because his motion for reconsideration relies on evidence he employed during his cross-examination of Officer Connley at the suppression hearing, rather than newly discovered evidence; and (2) the argument lacks merit because the mere fact that police surveilled another potential suspect did not prevent them from demonstrating probable cause to search the 3100 Vienna Woods residence.” United States v. Moore, 2024 U.S. Dist. LEXIS 119140 (S.D. Ohio July 8, 2024).*
A dog sniff at an apartment door from a common hallway was reasonable, even if the hallway also had a locked door. “Following the reasoning in Penaloza-Romero and Peck, and applying the Dunn factors, I find that the area around Defendant’s door is not curtilage under Eighth Circuit law and Jardines. While the first Dunn factor weighs in favor of a finding of curtilage, the remaining factors do not. The area around Defendant’s door was not surrounded by an enclosure (contrary to Defendant’s argument that the building itself constitutes an enclosure, I do not believe that the building itself is the type of enclosure contemplated by the concept of curtilage). The body camera video supports that the apartment door was not used for anything other than entering and exiting the apartment. Finally, while the exterior to the building was locked to passersby, the hallway and landings were open and used by other tenants, visitors, and apartment management. Accordingly, I find that the dog sniff was not illegal under the Jardines line of cases.” United States v. Copeland, 2024 U.S. Dist. LEXIS 118988 (N.D. Iowa July 8, 2024).
“Broussard’s counsel was not deficient for failing to challenge the ruling on Broussard’s suppression motion. No reasonable attorney could present Broussard’s flawed reading of the law on appeal and the search warrants were supported by ample probable cause. This argument would not have been ‘plainly stronger’ than the evidentiary issue that appellate counsel raised on appeal.” United States v. Broussard, 2024 U.S. Dist. LEXIS 118834 (D. Minn. July 8, 2024).*
Posted inCurtilage, Dog sniff, Ineffective assistance|Comments Off on N.D.Iowa: Dog sniff at apt door from common hallway was reasonable even if hallway was locked to outsiders
Failure to object at sentencing to a suspicionless search condition was waiver. United States v. Nash, 2024 U.S. App. LEXIS 16547 (2d Cir. July 8, 2024).
Defendant had a hearing on a motion to suppress that went undecided when he decided to plead guilty. The motion was a swearing match based on credibility. He doesn’t show that the motion would likely have been successful had it been ruled on. [How about just finding waiver and be done?] State v. O’Meara, 2024-Ohio-2602, 2024 Ohio App. LEXIS 2469 (11th Dist. July 8, 2024).*
Defendant had been parked and sitting at a gas pump for seven hours, and the police were called for a wellness check, and that resulted in finding a gun in plain view. United States v. Smith, 2024 U.S. Dist. LEXIS 118787 (D. Md. July 8, 2024).*
“LaGuardia argues that Officer Opperman lacked reasonable suspicion to extend the stop from a crash report to a DUI investigation. He claims that the officer investigated LaGuardia for DUI only because he abandoned his vehicle after the accident in snowy conditions. LaGuardia argues that the officer did not notice any signs of impairment or smell alcohol on his breath before he started the DUI investigation, but only thought he was trying to hide something. In other words, Opperman acted off a hunch, or something less, which falls short of reasonable suspicion. Pollman, 286 Kan. at 890 (an unparticularized hunch is not reasonable suspicion). We agree.” City of Overland Park v. LaGuardia, 2024 Kan. App. LEXIS 22 (July 5, 2024).
“McKoy now moves to disclose the identity of the confidential informant and also to suppress the evidence seized from the search of the apartment. I will deny the motion to disclose the identity of the confidential informant, because McKoy has not shown good reason to believe that disclosure is necessary for him to present a defense or to seek the suppression of evidence. On the other hand, McKoy has made enough of a showing to warrant an in camera interview of the confidential informant. I will deny the motion to suppress because McKoy has not made a substantial preliminary showing that there were any materially false statements or omissions in the search warrant affidavit that supported the search of the apartment.” United States v. McKoy, 2024 U.S. Dist. LEXIS 118925 (D. Conn. July 8, 2024).*
Merely driving another person’s car some doesn’t give standing. “Defendant (like the defendants in Rakas) has neither a property nor possessory interest in the vehicle and thus lacks standing to challenge the search of it. He did not have a property interest in Foster’s vehicle because the vehicle was registered to Foster, she was on the vehicle title, and she made payments on the vehicle. They were not married, and they did not own property together. Defendant also lacked a possessory interest in the vehicle at the time of the search. Foster was driving at the time of the encounter.” United States v. Harrison, 2024 U.S. Dist. LEXIS 119055 (D. Kan. July 8, 2024).
During a SWAT raid, decedent was asleep on the couch with a gun in his hand. When he woke from the commotion, he was killed when they saw the gun. Motion for judgment on the pleadings, with thus far undisputed facts denied. “Plaintiffs allege facts plausibly showing that Officer Hanneman’s use of force violated Amir’s clearly established Fourth Amendment rights. As presented at this stage, the body-worn-camera videos show Amir was armed, but they do not conclusively establish that Amir’s actions justified the use of deadly force. The City’s only argument for its separate dismissal depends on Officer Hanneman’s dismissal. Regardless, Plaintiffs allege plausible claims against the City. And Plaintiffs’ wrongful-death claim survives because the official-immunity rules by which this claim is judged under Minnesota law are comparable to the qualified-immunity inquiry under federal law.” Wells v. Hanneman, 2024 U.S. Dist. LEXIS 118832 (D. Minn. July 8, 2024).*
Posted inExcessive force, Standing|Comments Off on D.Kan.: Driving another person’s car some other times doesn’t give standing
Defendant’s motion for return of property is denied because the time hasn’t run for post-conviction and it still may be needed by the state. State v. Assad, 317 Neb. 20 (July 5, 2024).
Defendant did not present a real Franks issue by contesting that more detail was available because there was probable cause without it. United States v. Sanchez, 2024 U.S. Dist. LEXIS 118669 (N.D. Ohio July 8, 2024).*
Officers had a reasonable belief defendant was in a residence when they entered with an arrest warrant. They reasonably believed he was armed. The dispute was whether the gun was in plain view in a bedroom. But they didn’t readily find him. Officer “Monsalvo’s second search of the bedroom posed no greater intrusion than what had already occurred upon the arrest team’s initial entry into the home. On the other hand, the necessity of a second search at a time when Wilkes was still concealed somewhere in the home seems obvious given the totality of the circumstances.” They caucused on video about where else to look and whether there was a way into the crawl space. The gun was seen on a second entry, and it was a valid plain view. United States v. Wilkes, 2024 U.S. Dist. LEXIS 118600 (E.D. Mo. July 8, 2024).*
The officer here approached defendant in his parked car in an apartment complex parking lot without reasonable suspicion to inquire of what he was doing there. That ultimately led to an assault charge. Summarily reversed and dismissed without argument: There was no lawful justification for the stop in the first place, a requirement of state law. People v. Prude, 2024 Mich. LEXIS 1269 (July 5, 2024):
Defendant was convicted of DUI. Acting on a tip of erratic driving by a particular LPN, the officer went into her garage and entered it to investigate and then make the arrest. There were no exigent circumstances like a medical emergency, and the entry into the garage violated the Fourth Amendment and the state constitution. State v. Mellody, 2024 N.J. Super. LEXIS 55 (July 5, 2024):
Defendant attempting to thwart a search of cell phones in his car tried to break one such that it had to be forensically reviewed to get information off of it. He wasn’t under arrest. Still, his actions qualified for a 2 level obstruction enhancement under USSG § 3C1.1. United States v. Manning, 2024 U.S. App. LEXIS 16411 (8th Cir. July 5, 2024).
A USPS postal worker has no reasonable expectation of privacy in his workplace from video surveillance catching him opening mail. United States v. Alarcon-Rodriguez, 2024 U.S. Dist. LEXIS 118066 (D.P.R. July 2, 2024).*
No CoA here: Defendant’s ineffective assistance of counsel on a Franks claim fails here because defense counsel did argue about false information in the search warrant application. Defense counsel also argued staleness of the affidavit, and defendant only recasts the same argument but to no avail. Peterson v. United States, 2024 U.S. App. LEXIS 16377 (6th Cir. July 3, 2024).*
The FBI obtained a search warrant for the premises at US Private Vaults in Beverly Hills, California. The probable cause was based on a belief USPV was engaged in money laundering. The FBI went further and inventoried the safety deposit boxes. The inventory search was reasonable under FBI policy to inventory locked containers seized under a warrant and under the Fourth Amendment, and that led to this case in Pennsylvania. “For the reasons below, and having considered all record evidence in this matter, the Court finds that the FBI complied with the valid Warrants issued by Magistrate Judge Kim in inventorying the contents of Mr. Polk’s safe deposit box at USPV. Based on that holding, the Court proceeds with the understanding that the Government’s subsequent actions relative to Mr. Polk and his property were appropriate. Therefore, the Court finds that the Government complied with the Fourth Amendment to the United States Constitution in obtaining the evidence that it now seeks to use against Mr. Polk, a conclusion that leads the Court to DENY Mr. Polk’s Motion to Suppress Evidence (ECF No. 1266).” “Therefore, given all of the foregoing, the Government necessarily came into possession of the safe deposit boxes at USPV (including their contents), and the Government had every reason to inventory the contents of those boxes to not only identify their owners, but also to protect the agents handling the boxes, and to ensure that the owners of the boxes did not allege that the Government had removed any of the contents of the boxes before (potentially) returning those contents. In short, the mere fact that Mr. Polk’s identifying information was on Box 5911 did not eliminate the need for an inventory search of that Box.” United States v. Polk, 2024 U.S. Dist. LEXIS 117905 (W.D. Pa. July 3, 2024). For more information do a Google search of “U.S. Private Vaults”
Posted inInventory|Comments Off on W.D.Pa.: US Private Vaults safety deposit boxes in California could be inventoried by FBI leading to case here
"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.
