Category Archives: fourth amendment

Argument Recap: Guilt by association because we’re all criminals

The_Matrix_Reloaded_Burly_Brawl

It didn’t occur to me until earlier today, but there is a pattern here. The State has been trying for years to get great police powers at the expense of individual rights. But two things that happened in the last two days have really crystallized the extent to which they’re willing to go: 1. The absurd and frightening position staked out by the State of Connecticut at oral arguments yesterday, and; 2. Their repeated requests for vast investigative subpoena powers. I will take them up in turn.

The State of Connecticut thinks that everyone on the street is a suspect and the police should be able to detain anyone they feel like.

I wrote two days ago about the stunning argument the State is making in State v. Jeremy Kelly, where they are seeking to justify the detention of Kelly where he was only known to police officers as the guy standing next to someone they were looking for. Briefly, the police were looking for Gomez. They saw Burgos and Kelly. They thought Burgos was Gomez. They had no idea who Kelly was and were not interested in him. They ordered both men to stop. Both questioned that authority. The police repeated their commands. They both did not acquiesce and ran off. Kelly was eventually apprehended and charged with possession of cocaine.

The State argued that it did not need to show that there was any reason whatsoever to stop Kelly before making him submit to the police power of the State. The U.S. Supreme Court has said that a “brief, investigatory” stop is permitted where there is reasonable suspicion to believe that the person you are stopping has committed or is committing a crime. If you cannot show that reasonable belief, the stop violates the Fourth Amendment.

The State, though, urged the Supreme Court to adopt a ‘bright-line’ rule called the “Automatic Companion” Rule. It means essentially what you think it means: that the police should have the authority to automatically stop whomever is with someone they may think is committing a crime.

The hierarchy of standards goes something like this, from highest to lowest: beyond a reasonable doubt -> clear and convincing evidence -> preponderance of the evidence -> probable cause -> reasonable and articulable suspicion -> nothing.

So, R&AS is just a small step above nothing. It is slightly, but only just, more than a hunch. It requires that police officers put into words why they chose to stop someone as it relates to that person.

But no, this, apparently, is too difficult for the police. They want the power to stop everyone.

Failure to submit to government authority is evidence of a crime

I’ve already written once this week about the really stunning arguments the State is making to completely erode Fourth Amendment protections. And now, via John Wesley Hall, I see evidence that at least one state – North Carolina again – has gone completely batshit insane when it comes to the application of the prohibition against unreasonable searches and seizures.

So where we left off in that last post was that the police need particularized suspicion that a person is committing or has committed a crime in order to stop them for investigatory purposes. What I mentioned peripherally is that this applies to motor vehicles as well (Terry v. Ohio). What I didn’t mention is that the United States Supreme Court has explicitly held that two types of detentions of motor vehicles without particularized suspicion are okay: 1) DUI checkpoints (Michigan v. Sitz) and 2) stops where the purpose is not to investigate the person stopped but general investigation and information gathering (Illinois v. Lidster).

The rationale of both these cases is that these are not unreasonable intrusions into the protections afforded by the Fourth Amendment and that the minor inconvenience suffered by motorists pales in comparison to the overriding concerns of society: preventing drunk driving and catching criminals. [The Fourth Amendment provides that all people shall be free from unreasonable searches and seizures…]

The Supreme Court did set out some rules, however, in Michigan v. Sitz (the CT case is State v. Mikolinski): that

just as the Terry standard protects an individual’s freedom from arbitrary police conduct by requiring that a seizure “be based on specific, objective facts indicating that society’s legitimate interests require the seizure of the particular individual”; id.; so does the requirement “that the seizure must be carried out pursuant to a plan embodying explicit, neutral limitations on the conduct of individual officers.” Id.

Mikolinski. See also Delaware v. Prouse. So now, on to North Carolina. In State v. Kevin Griffin [PDF], the North Carolina Supreme Court has just held that a stop of a motor vehicle is legal under the Fourth Amendment to the Constitution where the only thing the motor vehicle did was turn around near a checkpoint.

Kevin Griffin was driving down a road, saw a checkpoint, made a legal turn away from the checkpoint and then was stopped by police officers.

Their reasonable and articulable suspicion that Kevin Griffin had committed or was committing a crime? That he turned away from the checkpoint.

Q. But he just made a left turn; is that correct?

A. Onto the shoulder, yes.

Q. That’s not an illegal turn; is it?

A. A left turn is not an illegal turn.

Q. And you never gave him a moving violation for that; did you not?

A. No.

The police state is here, folks. You will do what we tell you to do, otherwise you’re a criminal. This is the logical extension of those “search me, I’ve got nothing to hide” attitudes. A completely legal act – the left turn – is now evidence of a crime. “Sure we’ll search you and if you don’t let us, we’ll use that as evidence that you, in fact, do have something to hide.”

What’s next? Refusing to talk to a police officer on the street will now be sufficient evidence that you’ve got something to hide? So would it be okay then for the police to go up to people for no reason and start asking them incriminating questions? And if you refuse, well, then, you must be guilty of something, because only guilty people refuse to co-operate with the police and submit to their authority.

When we start giving up our rights in the name of security, they keep taking those rights. And then they’ll take every last scrap of freedom you have left and then you’re left staring at decisions where a man was suspected of committing a crime solely on the basis of a perfectly legal action.

We might as well just give up the ghost on this Fourth Amendment and install surveillance cameras in our houses and cars and workplaces because what is the point of having all this freedom? Wouldn’t it just be easier to let the Government have whatever it wants, hey as long as we’re not criminals, right?

War is peace
Freedom is slavery
Ignorance is strength

Oceania has always been at war with Eastasia.

The guilt by association exception to the Fourth Amendment

cat_group_pic

now which one-a-youz ates that bone?

Tomorrow at 10:00am, the Connecticut Supreme Court will hear argument in one of the most important cases to come before them in a long time. The case involves the authority of the police to stop and detain individuals just because they happen to be on a public street alongside someone the police might be looking for. In other words, the authority to automatically detain the companion of someone who is a suspect. In fewer words: guilt by association.

The defendant’s brief is here [PDF], the state’s brief is here [PDF] and the reply brief is here [PDF].

First, some setup. The Constitutional provision at play here is the Fourth Amendment, which protects against “unreasonable searches and seizures”. Normally, in order to enter a home or to arrest someone, the police need a warrant based on probable cause. In rare circumstances, a warrantless arrest or seizure can also be made, but it also must be justified by probable cause.

“[A] police officer is permitted in appropriate circumstances and in an appropriate manner to detain an individual for investigative purposes if the officer believes, based on a reasonable and articulable suspicion that the individual is engaged in criminal activity, even if there is no probable cause to make an arrest.”

State v. Clark; see also Terry v. Ohio. What that means is that even if an officer is making a brief investigatory stop, he has to be able to articulate a reasonable suspicion as to why he believes that particular person is engaged in criminal activity.

The facts. Got it? Okay. So, in State v. Kelly, police officers were looking for a guy named Gomez. They had the most generic of descriptions of Gomez before they set out that day: 20-22 year old Hispanic male. 5’5-5’7, 130-150lbs, medium complexion and very short hair. Everyone whom that description fits, raise your hands. They wanted to serve a warrant on him for violating his probation. They didn’t know how he had violated his probation or what he was on probation for. Despite their considerable resources, they hadn’t even bothered to look at a photo of Gomez before setting out.

They got a tip from one of their informants that Gomez might reside in the area of Brown Street in Wethersfield. So off they went, with only the most generic of descriptions. They come upon two men, Burgos and Kelly. While Burgos is Hispanic, he apparently had very lengthy hair. Kelly is African-American. So, in no way could Kelly be mistaken for Gomez.

Yet, the two officers decide to stop the two men and displaying their badges, motion for them to come over. [Under Connecticut state law, a broader definition of seizure applies than under the Federal Constitution – meaning we have greater protections. So a person is seized when a reasonable person would not feel free to leave a police encounter. State v. Oquendo.] Burgos asked “what for?” and Kelly said “I live here”. The police continued to order the men to come to them at which point they both took off running. For some reason, the police abandoned their chase of Burgos-who-they-thought-was-Gomez and focused on Kelly. They say him drop a baggie of something and he was eventually apprehended and charged with possession of cocaine.

The argument Kelly raises on appeal is essentially this: if, as described above, the police need particularized and individualized suspicion to infringe on someone’s Fourth Amendment right and the only reason they stopped him was because they were looking for Gomez, then his seizure and detention is in violation of the Constitution. The police admitted during the suppression hearing that they did not suspect Kelly of committing any crime when they stopped him and that they stopped him merely because he was walking next to the guy they thought they were looking for.

The State argues, however, that this violation of a Constitutional right is permitted because of the so-called “automatic companion” rule: that any time the police suspect that a person on the street is someone they are looking for or want to investigate, they have the authority to stop whomever else that person is with, in the name of officer safety.

The Appellate Court likened this situation to the line of motor vehicle stop cases in the United States Supreme Court, which has held that it is Constitutional for an officer to order a passenger out of the car during such a stop. Maryland v. Wilson. SCOTUS has also said it’s okay to detain passengers while the car is searched for contraband pursuant to a warrant. Michigan v. Summers.

Those cases, in my opinion, are quite different:

  • First, SCOTUS has carved out a very specific exception to the Fourth Amendment for motor vehicles due to their distinct nature. The automatic companion rule is not just an extension of the motor vehicle exception, but is another new comparable exception.
  • Second, passengers in a car are different than two people walking on a street. Passengers in a car are, by definition in some sort of companionship relationship together and, more importantly, it is physically impossible to stop a car and detain only one person inside while letting the others go on their way. That is not the case with two people walking on the street. It is far easier for officers to approach one individual – the one for whom they have reasonable and articulable suspicion or probable cause – while asking the others to step aside or go on their way. They are severable in a way that passengers in a car aren’t.
  • Finally, the motor vehicle cases presuppose that the entire car has been legally detained and then say that, once legally seized, to ask a passenger to step outside is a de minimis intrusion that is justified by officer safety. Here, that first step is at issue: is Kelly legally detained to begin with? The answer, of course, is no, unless you adopt the view that you do not need a specific particular individualized reason to stop him as long as he is with someone else whom you do have reason to stop.

The implications of permitting a rule whereby police can stop every person for whom they may or may not have reasonable suspicion and every companion in their immediate radius are frightening. One need only look at the allegations of racial profiling that have landed East Haven in trouble or the trial of the stop and frisk policies of New York City Police to know that permitting wholesale detention and seizure of people on inner city streets based on nothing more than “guilt by association” would result in, well…just look at these stats:

In 2010, New Yorkers were stopped by the police 601,285 times.
518,849 were totally innocent (86 percent).
315,083 were black (54 percent).
189,326 were Latino (33 percent).
54,810 were white (9 percent).
295,902 were aged 14-24 (49 percent).

In 2011, New Yorkers were stopped by the police 685,724 times.
605,328 were totally innocent (88 percent).
350,743 were black (53 percent).
223,740 were Latino (34 percent).
61,805 were white (9 percent).
341,581 were aged 14-24 (51 percent).

In 2012, New Yorkers were stopped by the police 533,042 times
473,300 were totally innocent (89 percent).
286,684 were black (55 percent).
166,212 were Latino (32 percent).
50,615 were white (10 percent).

If you think that’s a NYPD specific problem, look at these Philly PD allegations.

But it’s about more than all of that. It’s about the strength of our rights and the Constitution. Do we want an America where we can walk down the street and talk to whomever we want, without fear of being stopped by the police just because of the person next to us, even if they don’t suspect us of doing anything wrong?

Should we not require that bare minimum? If the police want to stop a person – any person – they should be required to say why they stopped that person that’s not “because he was talking to a drug dealer”? Talking to a dealer isn’t a crime. Our police forces shouldn’t have license to stop anyone they feel like without a suspicion that they are committing or have committed a crime. And, let’s be honest, that standard is absurdly low. Just look at their inept efforts to apprehend “Gomez” and how they bumbled into Burgos and Kelly instead. Was the stop of Burgos legal? How can we permit what happened to Kelly? And if this is permitted, what else will be?

 

This month at the Supreme Court: blockbuster session

not an actual judge

not an actual judge

I’m reviving a series I briefly dabbled in, back in 2008, called ‘This Month‘, which serves to preview the cases assigned for oral argument in the CT Supreme Court in the upcoming month. I may also include cases of special interest in SCOTUS, depending on whether I’m in the mood. I’ve also added a permanent link to this post in the sidebar, alongside the above picture, so you can find it at any time. The link will be updated every month to the most current ‘this month’ post.

The reason for reviving this is this upcoming April term, in which the court is scheduled to hear at least four cases that can have significant and profound impacts on the state of individual rights in Connecticut: State v. Kelly; State v. Brown, Brown v. Commissioner and State v. Santiago, impacting, in turn, the Fourth, Fifth, Sixth and Eighth Amendments.

The following is the listing of criminal cases scheduled for oral argument in the CT Supreme Court by date.

Monday, April 15 @ 10:00am: State v. Richard Annulli. [Briefs available here.] The defendant was charged with several sex related crimes. During the trial, he wanted to cross-examine the complaining witness to show that she was lying by questioning her about another separate instance in which she allegedly lied to the police in order to get someone else arrested. The trial judge, after hearing what that evidence would be, disagreed with the defendant’s characterization that she “lied” and thus did not permit the defendant to question her about that. The Appellate Court affirmed the conviction and the Supreme Court will review whether his Sixth Amendment right to confront one’s accuser was violated by the trial court. There is also a claim that the evidence was insufficient, but that’s going nowhere.

Tuesday, April 16 @ 10:00am: State v. Jeremy Kelly. The link to the left is to a separate post for this case. I don’t often engage in hyperbole but it is my opinion that this is one of the most important cases the CT Supreme Court will have to deal with for a while (except that other case coming up on April 23). This case involves the ability of the police to seize or detain groups of people when they have a reasonable suspicion to stop only one person out of that group. The implications of permitting such an “automatic companion” rule are staggering, especially for policing in minority neighborhoods, given the dubious “stop and frisk” tactics that are already employed there.

Wednesday, April 17 @ 10:00am: State v. Brown. [Briefs available here.] One of the fundamental concepts of the privilege against self-incrimination is that you have the right to remain silent. The police, pursuant to Miranda v. Arizona, generally advise a suspect of his rights. So, if a person chooses to invoke his rights and remain silent, that fact cannot be used to show that he is guilty. See Doyle v. Ohio. The question in Brown is whether post-arrest silence can be used against the defendant if the defendant first puts on evidence that he was co-operative with police and answered their questions. Has he, in essence, “opened the door” to harmful questioning? Once he does that, can the prosecutor show that when asked by the police how much he (in this case) had to drink, the defendant remained silent? The Appellate Court said yes and the Supreme Court will decide if that important protection of Due Process has an exception of these circumstances.

Interestingly enough, on the very same day, the United States Supreme Court will hear oral argument in Salinas v. Texas, in which the issue to be decided is whether the pre-arrest silence of a suspect can be used to show his guilt. [Greenfield has more here.]

Wednesday, April 17 @ 11:00am: State v. Stephen J.R. [Briefs available here.] The defendant, who was accused of sexually abusing the minor victim on four occasions, was charged with eight counts of sexual assault in the first degree and eight counts of risk of injury. At trial, the victim testified that the defendant abused her on “three or four” occasions and that she was forced to engage in two sexual acts each time. The defendant subsequently was convicted of all sixteen charges. He argues that the victim’s testimony was too vague to support the guilty verdicts on all sixteen charges, as she described generally what happened each time the abuse occurred but did not differentiate between the incidents. In addition, the defendant contends that the trial court, after conducting an in camera review of the records of the department of children and families pertaining to the victim and her family, improperly failed to fully disclose all of the relevant records. Finally, the defendant asserts that the prosecutor, during closing argument, improperly appealed to the emotions of the jury and thereby denied him a fair trial.

Thursday, April 18 @ 10:00am: O’Neil Brown v. Commissioner. [Briefs available here.] A case that will decide the applicability of Padilla v. Kentucky here in Connecticut. Padilla said that it was a lawyer’s responsibility to advise a defendant about any immigration consequences of a guilty plea. While Padilla was an important case for defendants going forward, the question here is whether it applies retroactively to people whose convictions are final and who may be awaiting deportation. While SCOTUS has said no, Chaidez v. US [PDF], they have also said that states are free to provide retroactivity under state law, Danforth v. Minnesota. Further, last year the Connecticut Supreme Court also said too bad you’re shit out of luck to a guy who sought to vacate his 1999 conviction because he was facing deportation in 2010 and no one told him that he could be deported. He relied on CGS 54-1j, but the Court said no, that only provides relief within the first three years. So O’Neil Brown is critical for defendants who may have pled guilty without any knowledge of the negative deportation consequences of that plea.

Monday, April 22 @ 10:00am: State v. Pires. The issue in this case is whether the defendant properly invoked his right to represent himself and whether that right was violated. The Appellate Court said no and the Supreme Court will review that decision.

Monday, April 22 @ 11:00am: State v. Mitchell Henderson. In 1993, the defendant was found guilty of several crimes and due to his extensive criminal record, was also found to be a persistent serious felony offender and a persistent dangerous felony offender, both of which triggered a greater punishment than normal. As a result of this, his sentence was lengthened or “enhanced”. In 2007, our Supreme Court decided that any such “enhancements” must be based on facts that are found by a jury beyond a reasonable doubt, rather than by a judge. So Henderson argued that his enhanced sentence is illegal because the facts weren’t found by a jury. The Appellate Court said no, the 2007 rule doesn’t apply backwards. The Supreme Court will now review.

Tuesday, April 23 @ 10:00am: State v. Eduardo Santiago. [Briefs available here.] This is the other big one this month, which will decide whether the prospective repeal of the death penalty is Constitutional or whether the entire death penalty needs to be scrapped or whether the repeal needs to be repealed. Keep in mind that the hearings on the racial and geographic disparity in the application of the death penalty are still pending.

Wednesday, April 24 @ 10:00am: State v. Milner. Here’s another fascinating case (and the last one of) this term. Milner was placed on probation in 2005. Sometime later, he was charged with a new crime and as a result of that, also charged with violating his probation. He apparently had a hearing on the violation of probation (VOP) first and a judge decided to revoke his probation and sentence him to jail. He appealed that judge’s decision. While that appeal was pending, he pled guilty to one of the new charges that formed the basis for the violation of his probation. He didn’t appeal that conviction (he couldn’t, really, because you typically can’t appeal from a guilty plea), but he did challenge its legality by filing a habeas corpus petition. The Appellate Court held that it wasn’t the same, his conviction was final and so his pending appeal (from the VOP) was moot. The Supreme Court will decide if that’s the case.

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If you have the briefs in any of these cases, please email them to me. If you’re going to see oral argument in any of these cases, please leave a comment with your observations.

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Image via. License details there.

 

 

 

 

No trespassing

I'm talking to you, officer.

I’m talking to you, officer.

[Update: See update at end of the post.]

Have you given strangers permission to come to the front steps of your house? Have you given a stranger permission to cross onto your property line and walk to the front door of your house? Certainly, none of us have given this explicit permission – we don’t post a sign at the edges of our property that “all are welcome”, but we have implicitly given some people permission to enter without our prior approval: the mailman, the neighbor borrowing sugar, the girls selling cookies, the cops with drug-sniffing dogs.

Wait, what? That’s precisely what happened in Florida v. Jardines [PDF], decided today by the United States Supreme Court and the State of Florida, along with 4 Supreme Court justices, argued that it was quite all right for cops to bring their drug sniffing dogs onto private property without a warrant in an attempt to sniff out illicit activity. Luckily for us and our individual rights, 5 members of the Court disagreed.

The case itself is an easy one to resolve, as both Justice Scalia’s majority opinion and Justice Kagan’s concurring opinion state: there is a physical intrusion onto your property by government agents:

The officers were gathering information in an area belonging to Jardines and immediately surrounding his house—in the curtilage of the house, which we have held enjoys protection as part of the home itself. And they gathered that information by physically entering and occupying the area to engage in conduct not explicitly or implicitly permitted by the homeowner.

The rest of the opinion is a good recap of some basic principles: what is a curtilage, was the intrusion unlicensed and that this “physical intrusion” test of Fourth Amendment jurisprudence is in addition to the standard “reasonable expectation of privacy” test of the Fourth Amendment.

And this is where, if this were a TV show, you’d hear the oft-used scratched record sound effect meant to imply halting.

Your rights are only worth the probable cause used to extinguish them

This, folks, is what happens when you don’t pay attention to the erosion of our collective rights. This is what happens when you steadfastly maintain an “us vs. them” attitude. This:

Maryland Deputy Attorney General WINFREE: But what I — the cornerstone of our argument is that when an individual is taken into custody, an individual is arrested on a probable cause, on a probable cause arrest, that person by virtue of being in that class of individuals whose conduct has led the police to arrest him on — based on probable cause surrenders a substantial amount of liberty and privacy.

If your eyes haven’t popped out of your head yet, you should check with an ophthalmologist. They may be stuck in place. The Government – Your Government – has brazenly started taking the tact in open court that simply by virtue of being arrested, an individual surrenders a “substantial amount” of liberty and privacy. I’m pretty certain she didn’t mean this in the literal sense of arrest and being locked up (which also has some requirements of balancing interests). This is in the sense that once you’re arrested, your rights are limited and you, by virtue of causing the police to arrest you, have forfeited privacy expectations and Constitutional rights.

Her argument, in that brief moment before Justice Kagan challenged her on it, was that by virtue of an arrest, an individual has voluntarily sacrificed his Fourth Amendment rights as is the issue in the case she was arguing.

Do you know what it takes to arrest someone? Next to nothing. You know the “ham sandwich” joke? Well probable cause is what they replaced grand juries with. And probable cause is whatever the hell they want it to be. It doesn’t have to be probable cause of the particular officer making an arrest, either and it can be based on completely innocuous every day actions of regular people.

I don’t normally say this, but thanks Justice Kagan:

JUSTICE KAGAN: But, Ms. Winfree, that can’t be quite right, can it? I mean, such a person, assume   you’ve been arrested for something, the State doesn’t have the right to go search your house for evidence of unrelated crimes; isn’t — isn’t that correct?

MS. WINFREE: That’s correct, Justice Kagan.

JUSTICE KAGAN: It doesn’t have the right to search your car for evidence of unrelated crimes.

MS. WINFREE: That’s correct.

JUSTICE KAGAN: Just because you’ve been arrested doesn’t mean that you lose the privacy   expectations and things you have that aren’t related to the offense that you’ve been arrested for.

Of course, what’s lost is that this State (Maryland) and the 49 other states that joined Maryland via an amicus brief already routinely take the position that once you’re arrested, you lose rights. (CT passed just such a bill last year. All my posts on DNA are here.)

In the case being argued, Maryland v. King, the Court is tasked with applying the Fourth Amendment to the 21st Century (is your computer’s recycle bin like your home’s trash can?). When someone is arrested for Crime A, can they take the person’s DNA and then enter it into a cold-case database to see if it matches any old crime. In King’s case, it did. He was then charged with and convicted of Crime B. At the time they took the DNA, they had absolutely zero suspicion that he was involved. It’s a routine procedure done with all arrestees.

These laws permit the collection of DNA from anyone who’s been arrested because they got into a drunken bar fight or because their boyfriend called the cops and said they were threatened or because a vindictive neighbor doesn’t like your dog pooping on his lawn or because you’re driving while black. And you have to give up your DNA, because the Man said so. And with that DNA, you give up your genome, your individual traits and characteristics.

You can read the oral argument transcript here and reports from SCOTUSBlog, the ABA Journal, the WaPo and the NYTimes to get a sense of how the court will rule. There are some Scalia zingers in there too. But I wanted to highlight this separate quote, for fear that it will get lost in the greater discussion.

And I want to keep asking that question: why aren’t you scared yet? Why don’t you care enough?

Justice Alito called this the “most important criminal procedure case this court has heard in decades”. He’s absolutely right. It’s time for the court to decide what’s more important: helping cops catch crooks or the individual liberties and freedoms of every citizen of this country. The answer’s clear to me. Is it to you?

13 realities of the Fourth Amendment

In what is quite possibly the most (only?) useful post ever written in the legal blogosphere, John Wesley Hall, author of a massive treatise of 4th Amendment Law, gives us a preview of the next edition with 13 “realities” of the 4th Amendment obvious to him after reading a shit-ton (that’s a legal term) of cases. Don’t be fooled. This is essentially a primer for 4th Amendment law. He’s giving away the outline here. Read it and memorize it and then come to the same conclusion that he does:

13. If you find you don’t completely understand the Fourth Amendment, you’re not alone because hardly anybody does any more. To me, much of the Fourth Amendment has turned into a Rorschach test that means different things to different people, all depending on how they want it to come out. How did just 54 words generate untolled [sic] millions of words in cases, treatises, and law review articles? The U.S. Supreme Court alone has decided about 250 Fourth Amendment cases.

I could’ve told you that, but it would have involved less information and more internet jokes. So, you’re welcome.