Falsely telling defendant that officers wouldn’t tow his car if he consented to a search made the consent involuntary. Here, the officer’s statement as to the law was false. Boitez v. Superior Court, 2023 Cal. App. LEXIS 859 (3d Dist. Nov. 7, 2023).
“[A] review of the record confirms the post-conviction court’s finding that counsel thoroughly litigated the motion to suppress, attacked the probable cause of the warrants, challenged law enforcement’s execution of the warrants, and argued that the warrants were overbroad. Thus, the district court properly concluded that Bowman was not entitled to relief on Claim 2.” Obviously no IAC and thus CoA. Bowman v. Sec’y, Dep’t of Corr., 2023 U.S. App. LEXIS 29658 (11th Cir. Nov. 6, 2023).*
The fact defendant’s cell phone had been seized but not searched before the search warrant application was made isn’t material to the probable cause showing for the warrant. United States v. Jackson, 2023 U.S. Dist. LEXIS 199739 (D. Vt. Nov. 7, 2023).*
There is no reasonable expectation of privacy in a license plate number. Officers can run any LPN number. They can also walk up to his car in his driveway and look at it. Becerra v. City of Albuquerque, 2023 U.S. App. LEXIS 29608 (10th Cir. Nov. 7, 2023).
Carpenter wasn’t the law when 2254 petitioner’s direct appeal was decided, so controlling SCOTUS caselaw wasn’t misapplied. Still, Stone applies, and he had a full and fair opportunity to keep litigating the issue. Jiles v. Kirkpatrick, 2023 U.S. Dist. LEXIS 199059 (W.D.N.Y. Nov. 6, 2023).*
One year was not stale in a child pornography case. United States v. Holland, 2023 U.S. App. LEXIS 29585 (11th Cir. Nov. 7, 2023).*
Officers parked their patrol car and were on foot patrol in a seriously high crime area and saw three young men working on a motorbike. As they approached, one could see the unmistakable “L” shape of a gun in the pocket of one. That led to a legitimate encounter. United States v. Terry, 2023 U.S. Dist. LEXIS 199374 (E.D. Va. Nov. 3, 2023).*
The cell phone search case of the CIA officer noted here from two weeks ago resulted in a guilty plea yesterday to some counts. NYT: Former C.I.A. Officer Pleads Guilty to Sexual Abuse Charges (“The former officer, Brian Jeffrey Raymond, 47, admitted that he had sexually assaulted dozens of women, dating back as far as 2006, both in the United States and overseas, federal prosecutors said.”)
Posted inCell phones|Comments Off on NYT: CIA officer’s cell phone search case pled yesterday
In a petition for return of property seized from a business, it was only required to show a possessory interest and likelihood of return. An evidentiary quality response isn’t required. State v. Allen, 2023-Ohio-4032, 2023 Ohio App. LEXIS 3869 (11th Dist. Nov. 6, 2023).
In a white collar case, the government seized cell phones during a search, and then it applied for warrants. Relying on common sense that cell phones are backed up and then synced when replaced, the government was able to show probable cause and the information was not stale as to other cell phones maybe that could not be shown to be associated with the crime. “In short, given the qualities of the electronic evidence sought and the long-term and ongoing nature of criminal conduct at issue, the passage of time as to some of the information known to Agent Williams did not render the facts supporting probable cause stale.” United States v. Watson, 2023 U.S. Dist. LEXIS 199071 (E.D.N.Y. Nov. 6, 2023).*
Based on investigation, “the Court finds that officers had reasonable suspicion to conduct an investigatory stop of Defendants’ vehicle and probable cause to arrest Defendants for financial exploitation of an elder.” Seizure of a cell phone for a later warrant was also reasonable. United States v. Brown, 2023 U.S. Dist. LEXIS 198843 (E.D. Tenn. Oct. 18, 2023),* adopted, 2023 U.S. Dist. LEXIS 197890 (E.D. Tenn. Nov. 3, 2023).*
It was permissible for officers to seize firearms seen in plain view during this protective sweep. United States v. Riley, 2023 U.S. Dist. LEXIS 198798 (S.D. Ohio Nov. 6, 2023).
“Given the totality of the circumstances and the numerous distinctions between this case and McNeely and Oaks, we conclude that the blood draw was justified by exigent circumstances. Unlike McNeely, once Defendant refused consent to a blood draw, Officer Millsaps began the process to obtain a warrant and did so as efficiently as possible. Officer Millsaps prepared the application and called the general sessions judge ‘at least five times,’ but the judge did not answer any of the calls. He then reached out to the on-call district attorney who advised him to proceed with the blood draw without a warrant under the circumstances.” State v. Davis, 2023 Tenn. Crim. App. LEXIS 451 (Nov. 6, 2023).*
“Here, as the People correctly concede, the detective’s on-the-scene observations during the two controlled drug buys fell short of probable cause without the information provided to him by the CI. Although the detective saw the CI walk toward the subject building and later return to the predesignated meeting location, he was unable to confirm that the CI had actually purchased the narcotics from the subject apartment (see People v Nettles, 172 AD3d at 1103-1104).” People v. Huginnie, 2023 NY Slip Op 05516 (2d Dept. Nov. 1, 2023).* (This is a NY only issue.)
Defense counsel wasn’t ineffective for not filing a motion to suppress property that wasn’t his but where he spent time. The trial strategy was to distance defendant from the property, and asserting a reasonable expectation of privacy in the property tied him to it. Horton v. State, 2023 Tenn. Crim. App. LEXIS 449 (Nov. 6, 2023).
Defendant’s car was searched by the police finding only a shell casing. It was to be towed and the tow truck driver, freeing a stuck gearshift, found a gun hidden in the console, and he called the police. The tow truck driver was a private actor, and no motion to suppress would have succeeded. United States v. Dejean, 2023 U.S. Dist. LEXIS 198493 (E.D. La. Nov. 6, 2023).*
Plaintiff’s claim against an animal rights group that procured a search warrant for dogs locked in a garage fails because there was probable cause. Barraclough v. Animal Friends, Inc., 2023 U.S. Dist. LEXIS 198529 (W.D. Pa. Nov. 6, 2023).*
There was no corroboration of the incriminating part of the CI’s tale that defendant, a convicted felon, kept a gun hidden under the hood of his car. “But Officer Princivalli had no reason to find Moore’s statements untrustworthy or unreliable. In fact, he verified several of them–the vehicle was rented and Mitchell was violent–before the search. The district court did not err in determining that the search was warranted under the automobile exception.” United States v. Mitchell, 2023 U.S. App. LEXIS 29447 (8th Cir. Nov. 6, 2023).
A few weeks was not too stale in a child pornography case. Over 1,000 images were recovered. United States v. Long, 2023 U.S. App. LEXIS 29502 (11th Cir. Nov. 6, 2023).*
Alleged violation of state bail law that apparently resulted in defendant spending a bit more time in jail before bonding out did not support a Fourth Amendment claim under Riverside. Otherwise, it was reasonable. Oaks v. Rowald, 2023 U.S. Dist. LEXIS 198320 (S.D. Ill. Nov. 3, 2023).*
Plaintiff stated a claim for excessive force at this stage of the case. The law was clearly established, and a jury could find against the officer. Hughes v. Herbster, 2023 U.S. Dist. LEXIS 198335 (M.D. Pa. Nov. 3, 2023).*
NYLJ: Section 1983 Fabricated Evidence Claims—Focus on ‘Barnes v. City of New York’ (“Police fabrication of evidence gives rise to a steady stream of § 1983 fabrication of evidence claims, which frequently raise important, difficult legal issues. The recent decision in ‘Barnes v. City of New York’ illustrates some of the complications that can arise.”)
Posted in§ 1983 / Bivens|Comments Off on NYLJ: Section 1983 Fabricated Evidence Claims—Focus on ‘Barnes v. City of New York’
The district court decided this vehicle search on inventory. On appeal, the court goes with search incident because the vehicle was being driven with improper dealer tags. Officer “Hobbs’s search of the glovebox incident to Travis’s arrest was proper. Evidence of a vehicle’s ownership and registration is regularly contained in the glovebox of a vehicle. Evidence of ownership would bear directly on whether it was illegal for Travis to operate the car with dealer plates.” United States v. Travis, 2023 U.S. App. LEXIS 29386 (7th Cir. Nov. 3, 2023).
“In the present case, the plaintiff appears to claim that the defendants illegally obtained his cell phone records and used them against him in his underlying criminal prosecution. The plaintiff’s appellate brief, however, is nearly incomprehensible.” “The omissions in the plaintiff’s brief lead us to conclude that the plaintiff has abandoned his claims.” Stanley v. Scott, 2023 Conn. App. LEXIS 256 (Nov. 7, 2023).*
Where probation had ended, a probation search could not occur. Also, he did not consent. State v. Simons, 315 Neb. 415 (Nov. 3, 2023).*
Defendant’s motion to withdraw his guilty plea is denied. During the plea colloquy he asked even whether a search warrant could be issued on hearsay. The plea was voluntary. United States v. Coleman, 2023 U.S. Dist. LEXIS 198232 (D.D.C. Nov. 1, 2023).*
The search warrant for defendant’s email accounts to show where he was when he accessed it, “evidence relating to the planning, execution, furtherance and/or concealment of the crimes under investigation,” and his “and other participants’ state of mind as it relates to the crimes under investigation” was not overbroad. United States v. Shemtov, 2023 U.S. Dist. LEXIS 197514 (N.D. Ga. Nov. 3, 2023). [Still, to me, it leaves way too much to the discretion of the officer executing the warrant to be valid, but then the good faith exception would probably save it anyway. As to this man, he would lose, but the law would hopefully be settled.]
Pro se plaintiff’s complaint that his cell phone was searched without a warrant by police was answered with a motion to dismiss that the statute of limitations had run. It probably has, but he gets leave to amend to try and fix it if he can. Dicks v. Fipps, 2023 U.S. Dist. LEXIS 197534 (M.D. Fla. Nov. 3, 2023).*
Plaintiff believed to have caused a “SWATting” where an innocent man was set up for a police raid. The delays in the investigation that lengthened his detention lacked justification and the officers get no qualified immunity for that. Reitz v. Woods, 2023 U.S. App. LEXIS 29165 (5th Cir. Nov. 2, 2023).*
Defendant fled from the police in his car in a highspeed chase. They went to his house and came on to defendant’s curtilage, his porch, and shined flashlights through the windows. This was a search on a constitutionally protected area. The officers’ continued knocking and ordering him out was a seizure, even though they did not actually come in. The proffered emergency exceptions do not apply. The motion to suppress his blood draw and statements is granted. United States v. McGrath, 2023 U.S. Dist. LEXIS 198008 (M.D. Pa. Nov. 2, 2023).
Defendant’s stop was based on a BOLO and he and his location clearly matched the report. After the stop he consented to a search. Webb v. State, 2023 Ala. Crim. App. LEXIS 54 (Nov. 3, 2023).*
Defendant had no reasonable expectation of privacy when he was seen masturbating in his prison cell, if that was even a search. State v. Lewis, 2023-Ohio-4010 (7th Dist. Nov. 2, 2023).*
The USMJ held that the warrant was issued with particularity and denied the motion to suppress. There were no objections. United States v. Quinones, 2023 U.S. Dist. LEXIS 197910 (W.D.N.Y. Nov. 3, 2023).*
Conclusory statement of standing in a rented vehicle fails without some proof. “Defendant’s expectation of privacy rests on his contention that he rented the Taurus on Turo and lacked knowledge of the possibly stolen character of the vehicle. But if Defendant relies on a lack of knowledge to establish a reasonable expectation of privacy in the Taurus, he bears the burden of proof on such facts.” United States v. Thomas, 2023 U.S. Dist. LEXIS 197727 (D. Nev. Nov. 3, 2023).
The government seized defendant’s cell phone but waited nine months to get a search warrant to search it. Motion to suppress granted for the delay. United States v. Martinez, 2023 U.S. Dist. LEXIS 197629 (D. Ariz. Nov. 3, 2023).
The application under the SCA for records and information about defendant’s cell phone records complied with the law at the time. United States v. Miske, 2023 U.S. Dist. LEXIS 197693 (D. Haw. Nov. 3, 2023).*
Plaintiff is a Suffolk County police officer on work-related sick leave. He was ordered to take a drug test while off, and the court finds it a search and done on reasonable suspicion. Volpe v. Ryder, 2023 U.S. Dist. LEXIS 197057 (E.D.N.Y. Nov. 2, 2023).*
The defendant officer here got qualified immunity for a malicious prosecution claim on plaintiff’s 2004 charging in a 2002 crime. Plaintiff was convicted but it was set aside because of “recanted testimonies.” Any right was clearly established back then. Weimer v. Cty. of Fayette, 2023 U.S. App. LEXIS 29208 (3d Cir. Nov. 2, 2023).*
“This appeal arises from a protest of the Dakota Access Pipeline at the Backwater Bridge in Morton County, North Dakota. Police officers deployed water, tear gas, rubber bullets, and bean bags to disperse a crowd.” “We conclude that the protestors have not established that the individual officers violated a clearly established right under the Fourth Amendment, because it was not clearly established as of November 2016 that use of force to disperse the crowd was a seizure.” A due process claim was not developed to show a clearly established right” there, either. Dundon v. Kirchmeier, 2023 U.S. App. LEXIS 29224 (8th Cir. Nov. 3, 2023).*
Defendant fled in his car from a traffic stop and wrecked a few blocks away. He abandoned the car at the scene by running off. Commonwealth v. Hall, 2023 PA Super 224, 2023 Pa. Super. LEXIS 513 (Nov. 3, 2023).
“Defendant further appears to argue that a search warrant issued against him was invalid because it rested on an invalid identification of him as the shooter. His argument, however, lacks clarity and is interspersed with references to the allegedly improper grand jury proceedings. Defendant also questions the credibility of some of the State’s witnesses, but does so in the context of his argument against the warrant.” As a motion to suppress, this is completely undeveloped [and off the mark]. State v. Johnson, 2023 La. App. LEXIS 1806 ( La. App. 3 Cir. Nov. 2, 2023).*
Defendant was detained in part because he was an alleged missing person but he didn’t have a valid DL on him. The delay in waiting for the drug dog was attributable to defendant’s own actions. Ramsey v. State, 2023 Ind. App. LEXIS 316 (Nov. 2, 2023).*
Defendant was a Venezuelan attorney whose cell phone was searched at the border. He said there likely was privileged attorney-client information on his phone, but it was searched under a DHS protocols to safeguard privileged information and legal advice was sought from an agency attorney before doing it. “The government took adequate precautions to safeguard against disclosing privileged material: the agents consulted with in-house counsel about how to handle the phones given privilege concerns; they limited their initial search to only pictures and videos, not text, to avoid discovering any attorney-client communications; and they obtained a warrant and assembled a filter team before more fully examining the phones’ contents. And ultimately, no privileged material was ever found. We thus find no error in the district court’s denial of Fonseca’s motion to suppress.” United States v. Fonseca, 2023 U.S. App. LEXIS 29217 (11th Cir. Nov. 3, 2023).
“All three Graham factors weigh in favor of Deputy Dailey and against Hansen. Deputy Dailey’s use of force was reasonable. This is particularly true given that Deputy Dailey’s decision to shoot Arbuckle once she began to reverse is the ‘type of split-second judgment, “made in tense, uncertain, and rapidly evolving” circumstances, “that [courts] do not like to second-guess using the 20/20 hindsight found in the comfort of a judge’s chambers.”’ Estate of Valverde, 967 F.3d at 1049. Because all the Graham factors weigh in favor of Deputy Dailey, we conclude that his actions were reasonable under the specific circumstance that he encountered. Deputy Dailey did not violate Arbuckle’s Fourth Amendment right to be free from excessive force. Therefore, Hansen has not met his burden to demonstrate that Deputy Dailey violated Arbuckle’s constitutional rights, and Deputy Dailey is thus entitled to qualified immunity.” Hansen v. Dailey, 2023 U.S. App. LEXIS 29079 (10th Cir. Nov. 2, 2023).*
Posted inBorder search, Cell phones, Excessive force, Privileges|Comments Off on CA11: Gov’t adequately protected against A-C materials being searched in border search of Venezuelan attorney’s cell phone; “no privileged material was ever found”
Whether defendant’s stop was valid or not, her giving a false name and DOB was an independent crime that would not be suppressed. State v. Hellinger, 2023 N.H. LEXIS 188 (Nov. 2, 2023).
Defendant’s posture driving an open air Jeep suggested that he was talking on a cell phone cradling it between shoulder and ear. That was reasonable suspicion for a stop in a hands free state. His failure to articulate a reason for the state constitution to be interpreted more broadly is waiver. State v. Garitone, 2023 Ida. App. LEXIS 27 (Nov. 2, 2023).*
There was probable cause for the search warrant for defendant’s digital devices for child porn, and 52 were recovered. The good faith exception also applied. United States v. Rohani, 2023 U.S. Dist. LEXIS 196823 (D. Or. Nov. 2, 2023).*
Posted inProbable cause, Reasonable suspicion|Comments Off on NH: False information to officer during stop is independent crime even if stop illegal
The city wrote by certified mail to the owner of rat-infested property apparently abandoned since he hadn’t come from home in California since before Covid. State law allows inspections if requested and permitted. The owner never responded. His Fourth Amendment rights weren’t violated by the entry to determine whether the building should be torn down or ordered repaired. City of New Lisbon v. Muller, 2023 Wisc. App. LEXIS 1150 (Nov. 2, 2023).
Defendant claims in his 2255 that he believed at the time he pled that evidence in a trash pull was planted by the police. He didn’t challenge the factual basis for the plea and it fails now. LeSane v. United States, 2023 U.S. Dist. LEXIS 195663 (E.D.N.C. Oct. 31, 2023).*
Once again in this state, the fact a drug dog can’t distinguish between legal hemp and marijuana isn’t a basis to suppress. State v. Major, 2023 Tenn. Crim. App. LEXIS 441 (Oct. 31, 2023).*
Posted inAdministrative search, Consent, Dog sniff|Comments Off on WI: Failure to respond to City’s letter to inspect rat-infested property was implied consent
Defendant doesn’t get to see the affidavit for warrant yet just for his bail application because the government asserts the investigation is still ongoing. Discovery of child pornography was inadvertent, and the bail application isn’t a discovery device. The question is whether he is a danger to the community or would flee, and child porn defendants get released all the time. In re Search Warrant Dated October 4, 2023, 2023 U.S. Dist. LEXIS 196629 (S.D.N.Y. Nov. 1, 2023).
Defendant’s probation search conditions explicitly included his electronic devices, and the search here was with reasonable suspicion. United States v. Lajeunesse, 2023 U.S. App. LEXIS 28975 (2d Cir. Nov. 1, 2023).*
Defendant was legitimately detained as a visitor on the premises under Michigan v. Summers when the search warrant was being served, and then he consented to search of his vehicle. United States v. Hernandez, 2023 U.S. Dist. LEXIS 196172 (S.D. Fla. Oct. 17, 2023).*
Posted inComputer and cloud searches, Overbreadth|Comments Off on techdirt: Court Rejects Extremely Broad Google Search Warrant, Citing Both Carpenter And Riley
The search warrant here was for delta-8,9,10-THC but 8 and 10 are not controlled substances. Lacking probable cause for them, the search target is entitled to return of its property. Elements Distribution v. State, 2023 Ga. App. LEXIS 535 (Nov. 2, 2023).
Defendant was met with drawn weapons and officers shouting profanities when he opened his door. His actual consent, however, was separated from that after things calmed down. United States v. McGhee, 2023 U.S. Dist. LEXIS 194988 (N.D. Ala. Sep. 27, 2023).*
Defendant didn’t show standing in the place searched that was lived in by someone else. He also effectively abandoned the argument by not challenging the R&R. United States v. Davis, 2023 U.S. Dist. LEXIS 195179 (E.D. Tenn. Oct. 31, 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.
