Archive for the ‘Fourth Amendment’ Category

Supreme Court To Hear Key Fourth Amendment Case

On Wednesday, the Supreme Court will hear Carpenter v. United States, a case experts are calling the most important privacy issue before the court in a generation. At issue, according to SCOTUS blog, is Whether the warrantless seizure and search of historical cellphone records revealing the location and movements of a cellphone user over the course of 127 days is permitted by the Fourth Amendment.

Given that nine out of ten adults in America use some kind of cell phone, a number that has increased substantially since even a decade ago, this decision regarding electronic communications and Americans privacy and property rights will be landmark.

Between December 2010 and March 2011, a group of friends in the Detroit area robbed several RadioShack and T-Mobile stores in Michigan and Ohio. Ironically, they chose to steal cell phones (note: if you steal something, dont steal an item that can be tracked). A month after the spree, four of the thieves were arrested, but not the mastermind of the scheme, Timothy Carpenter. A guilty compatriot turned over his phone, and FBI agents reviewed the calls he had made around the time he and his buddies were snatching cell phones.

Because of the Stored Communications Act, a judge granted an order for the FBIs request to obtain transactional records from wireless carriers for multiple phone numbers for [a]ll subscriber information, toll records and call detail records including listed and unlisted numbers dialed or otherwise transmitted to and from [the] target telephones [] as well as cell site information for the target telephones at call origination and at call termination for incoming and outgoing calls[.] The judge didnt grant a warrant, which would have required probable cause, and which law enforcement did not yet have.

This is where the infamous Carpenter comes in. From the records, law enforcement was able to figure out that one of the thieves had been in touch with Carpenter and, because of which cell phone towers Carpenters phone pinged, that he had been near the robberies. This led to Carpenter being arrested, convicted by a jury, and sentenced to 116 years in prison.

At first, it might not seem like there is an issue at here at all. The rub, however, lies in whether a judge can grant a warrantless search of cell phone records that reveal the phones (and thus users) whereabouts without violating the Fourth Amendment. Recall, the Fourth Amendment protects [t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures[.] Without the police search of digital data, its possible Carpenter may never have been linked to the robberies or arrested, or the police would have had to dig up better hard evidence to get him convicted.

As the Washington Post explained, The government may only violate these rights upon issuance of a warrant. The Fourth Amendment protections include the publics content of their communications; however, federal courts have long recognized that the Fourth Amendment does not protect the public from allowing the government to obtain the information necessary to get communications from point A to point B. For example, the government can obtain from a letter or package without a warrant the sender, receiver, originating and delivery addresses, package size, and weight; however, the government must obtain a warrant before opening the package or letter to obtain its contents.

SCOTUS already has a precedent regarding phone communications. In Smith v. Maryland, the court held the government may not eavesdrop on a phone call but could obtain without a warrant the phone numbers the person dialed. In 1986, the Congress passed the Stored Communications Act, which governs the privacy of stored Internet communications.

The government is expected to rely upon these decisions to make its case that the warrantless search of Carpenters calls and cellphones whereabouts did not violate his Fourth Amendment rights. Carpenter will undoubtedly lean heavily on the Fourth Amendment itself and Riley v California to make the case that, as Lawfare said, cell phones have become intertwined into the lives of American citizens and the vast data contained within a persons phone potentially holds the sum of the individuals private life, so the routing data contains much more than the information necessary to get communications from point A to point B.

The juxtaposition between the way the Fourth Amendment is written and how much technology has advanced since those times lies at the heart of legal stickiness here. What constitutes houses, papers, and effects? Are cell phones, the digital data within them, and information retrieved from the cell towers from which that data bounces and databases communications companies keep to provide their services? And what exactly is a search? Must it be physical trespassing, or could it be digital maneuvering through computer search or even a hack?

The late Justice Scalia was famously a Fourth Amendment originalist, as obvious in his dissent in Kyllo v United States, which held in a 54 decision that using thermal imaging was a search and required a warrant. But the advancement of time and technology makes cases like this unusually difficult to interpret. As Lawrence Rosenthal, a law school professor, wrote:

Justice Scalias Fourth Amendment originalism hangs by a thread []Sometimes Justice Scalia himself seemed to acknowledge the difficulty of applying founding-era doctrine to contemporary contexts, as when, in 2014, he joined a unanimous Court in Riley v. California in holding that information in cellphones could not be retrieved without a warrant, despite the traditional rule that permitted police to search an arrestees person and effects incident to arrest.

Several reputable organizations have filed amicus (friend of the court) briefs in favor of Carpenter, including the Cato Institute, the Electronic Frontier Foundation, and the American Civil Liberties Union. They argue digital data is personal property.

Time will tell how the Supreme Court decides.

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Supreme Court To Hear Key Fourth Amendment Case

4th Amendment – constitution | Laws.com

Fourth Amendment:Searches and Seizures

What is the Fourth Amendment?

The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.

The Fourth Amendment Defined:

Like the majority of fields within American law, the Fourth Amendment is heavily rooted in the English legal doctrine. In a general sense, the Fourth Amendment was created to limit the power of the government and their ability to enforce legal actions on individuals. The Fourth Amendment was adopted as a direct response to the abuse of the writ of assistance, which was a type of general search warrant used by the government during the American Revolution. The Amendment was created to limit the powers of the law enforcement agency who is conducting a search of an individuals personal property.

The Fourth Amendment is a part of the Bill of Rights, which are the first 10 Amendments to the United States Constitution and the framework to elucidate upon the freedoms of the individual. The Bill of Rights were proposed and sent to the states by the first session of the First Congress. They were later ratified on December 15, 1791.

The first 10 Amendments to the United States Constitution were introduced by James Madison as a series of legislative articles and came into effect as Constitutional Amendments following the process of ratification by three-fourths of the States on December 15, 1791.

Stipulations of the 4th Amendment

The Fourth Amendment guards against the governments ability to conduct unreasonable search and seizures when the individual party being searched has a reasonable exception of privacy.

The Fourth Amendment specifically requires a law enforcement agency to possess judicially sanctioned search and arrest warrants, which are supported by probable clause, to be administered before a persons property can be inspected.

The Fourth Amendment ties in numerous limitations whereby an individual may be searched without a warrant given the presence of certain circumstances. The individuals property may be searched and seized if: The individual is on parole or in a tax hearing, faces deportation, the evidence is seized from a common carrier, the evidence is collected by U.S. customs agents, the evidence is seized by probation officers, the evidence is seized outside of the United States, or probable cause is evident.

Court Cases tied into the 4th Amendment

In Mapp v. Ohio, the Supreme Court ruled that the Fourth Amendment is enforceable and should be applied to all states in the Union by way of the Due Process Clause of the Fourteenth Amendment. Additionally, the Supreme Court ruled that certain searches and seizures were in direct violation of the Fourth Amendment even when a warrant was properly issued to the coordinating law enforcement agencies.

State Timeline for Ratification of the Bill of Rights

New Jersey:November 20, 1789; rejected article II

Maryland:December 19, 1789; approved all

North Carolina:December 22, 1789; approved all

South Carolina: January 19, 1790; approved all

New Hampshire: January 25, 1790; rejected article II

Delaware: January 28, 1790; rejected article I

New York: February 27, 1790; rejected article II

Pennsylvania: March 10, 1790; rejected article II

Rhode Island: June 7, 1790; rejected article II

Vermont: November 3, 1791; approved all

Virginia: December 15, 1791; approved all

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The Fourth Amendment and querying the 702 database for …

An interesting Fourth Amendment issue has come up in debates over the reauthorization of Section 702 of the Foreign Intelligence Surveillance Act. This is the authority, some will recall, that allows the government to collect from inside the United States the contents of communications of foreigners reasonably believed to be outside the United States without obtaining a warrant. Heres the question, as I understand it: If a foreigner (a non-United-States person, in the statute) is communicating with a U.S. citizen inside the United States, and the government has collected the communications between them under Section 702 by targeting the foreigner, what are the Fourth Amendment limits on querying the database to find evidence of criminal activity committed implicating the United States person? In other words, after the government has collected the contents under the national security authorities based on the non-U.S. person, what are the limits on switching over to a criminal query that targets the U.S. person?

As I understand the intelligence communitys position, it takes the view that querying the database is always okay because its not an additional Fourth Amendment search. The Fourth Amendment governs collection of the contents of the communications, but not the separate query. From Q&A posted earlier this year:

Querying databases containing Section 702 information does not result in any new acquisition of data; it is instead only an examination or re-examination of previously acquired information. Therefore, those queries are not separate searches for Fourth Amendment purposes. The IC queries its databases to more quickly and efficiently sort and identify communications already lawfully collected, such as information potentially related to a terrorist plot against the United States, without having to sift through each individual communication that has been collected.

I dont find this persuasive. As I understand this, Section 702 raw data has been collected but not yet observed. In Fourth Amendment law, it has been seized but not searched. See Soldal v. Cook County (1992). As a result, the data maintains the Fourth Amendment protection it had before it was copied.

Its true that, after data has been exposed to human observation, it has been searched and Fourth Amendment search rights expire. Once that exposure has happened, the data can be used and reanalyzed in any way the government wants without it being another search. See Illinois v. Andreas (1983). But the mere copying of data without human observation is a seizure but not a search, I think. Thats why courts scrutinize how the government searches images of seized hard drives or the copies of email accounts obtained from service providers. If the data has been copied but not searched, querying it is a search. Or so it seems to me.

Granted, there is a circuit split right now on the private-search reconstruction doctrine that might be relevant. The split concerns how much is searched when a private party sees a file on the hard drive: Is just the exposed data searched, or the file, or even the entire physical storage device? Its fair to assume, although not entirely obvious, that the answer to that also sheds light on what is searched in the government context. But even so, it seems hard to believe that a court would say that observing some files in a massive government database of unsearched contents extinguishes all Fourth Amendment rights in that data.

If Im right about that, then the query through the raw 702 database requires its own Fourth Amendment justification. Im not sure what warrant exception could apply, though. Its a query for criminal investigative purposes, as I understand the hypo, so no national security reasonableness exception could apply. Its targeting the U.S. persons communications, so presumably its outside the reasonableness framework unpersuasively invented by the Ninth Circuit in the Mohamud case. Maybe theres some other way to get around a Fourth Amendment warrant requirement here, but its not clear to me what it is.

Im not saying I have the answers to this question. And maybe I am misunderstanding the question itself. But based on the public discussions I have seen about what is happening, I worry that there is a lot more of Fourth Amendment concern here than the government is acknowledging.

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The Fourth Amendment and querying the 702 database for ...

Fourth Amendment Freedoms are Being Choked, Guilty until Proven Innocent – Center for Research on Globalization

The Fourth Amendment was designed to stand between us and arbitrary governmental authority. For all practical purposes,that shield has been shattered, leaving our liberty and personal integrity subject to the whim of every cop on the beat, trooper on the highway and jail official.Herman Schwartz,The Nation

Our freedomsespecially the Fourth Amendmentare being choked out by a prevailing view among government bureaucrats that they have the right to search, seize, strip, scan, shoot, spy on, probe, pat down, taser, and arrestanyindividual atanytime and for theslightestprovocation.

Such is life in America today that Americans are being made to relinquish the most intimate details of who we areour biological makeup, our genetic blueprints, and our biometrics (facial characteristics and structure, fingerprints, iris scans, etc.)in order to clear the nearly insurmountable hurdle that increasingly defines life in the United States:we are now guilty until proven innocent.

Forced cavity searches, forced colonoscopies, forced blood draws, forced breath-alcohol tests, forced DNA extractions, forced eye scans, forced inclusion in biometric databases: these are just a few ways in which Americans are being forced to accept that we have no control over our bodies, our lives and our property, especially when it comes to interactions with the government.

Consider, for example, what happened to Utah nurse Alex Wubbels after a police detective demanded to take blood from a badly injured, unconscious patient without a warrant.

Wubbels refused, citing hospital policy that requires police to either have a warrant or permission from the patient in order to draw blood. The detective had neither. Irate, the detective threatened to have Wubbels arrested if she didnt comply. Backed up by her supervisors, Wubbels respectfully stood her ground only to beroughly grabbed, shoved out of the hospital, handcuffed and forced into an unmarked carwhile hospital police looked on and failed to intervene (take a look at the policebody camera footage, which has gone viral, and see for yourself).

Michael Chorosky didnt have an advocate like Wubbels to stand guard over his Fourth Amendment rights. Chorosky was surrounded by police, strapped to a gurney and thenhad his blood forcibly drawn after refusing to submit to a breathalyzer test.

What country is this? What country is this? cried Chorosky during the forced blood draw.

What country is this indeed?

Unfortunately, forced blood draws are just the tip of the iceberg when it comes to the indignities and abuses being heaped on Americans in the so-called name of national security.

Forced cavity searches, forced colonoscopies and forced roadside strip searches are also becoming par for the course in an age in which police are taught to have no respect for the citizenrys bodily integrity whether or not a person has done anything wrong.

For example, 21-year-old Charnesia Corley wasallegedly being pulled over by Texas police in 2015for rolling through a stop sign. Claiming they smelled marijuana, police handcuffed Corley, forced her to strip off her pants, threw her to the ground,forced her legs apartand then probed her vagina. The cavity search lasted 11 minutes. This practice is referred to as rape by cop.

David Eckert was forced to undergoan anal cavity search, three enemas, and a colonoscopyafter allegedly failing to yield to a stop sign at a Wal-Mart parking lot. Cops justified the searches on the grounds that they suspected Eckert was carrying drugs because his posture [was] erect and he kept his legs together. No drugs were found.

During a routine traffic stop, Leila Tarantino was subjected to two roadside strip searches in plain view of passing traffic, while her two childrenages 1 and 4waited inside her car. During the second strip search, presumably in an effort to ferret out drugs,a female officer forcibly removed a tampon from Tarantino. No contraband or anything illegal was found.

Thirty-eight-year-old Angel Dobbs and her 24-year-old niece, Ashley, werepulled over by a Texas state trooperon July 13, 2012, allegedly for flicking cigarette butts out of the car window. Insisting that he smelled marijuana, the trooper proceeded to interrogate them and search the car. Despite the fact that both women denied smoking or possessing any marijuana, the police officer then called in a female trooper, who carried out a roadside cavity search,sticking her fingers into the older womans anus and vagina, then performing the same procedure on the younger woman, wearing the same pair of gloves. No marijuana was found.

Meanwhile, four Milwaukee police officers were charged with carrying out rectal searches of suspects on the street and in police district stations over the course of several years. One of the officers was accused of conducting searches of mens anal and scrotal areas, ofteninserting his fingers into their rectumsand leaving some of his victims with bleeding rectums.

Its gotten so bad that you dont even have to be suspected of possessing drugs to be subjected to a strip search.

Thanks to the U.S. Supreme Courts ruling inFlorence v. Burlison, any person who is arrested and processed at a jail house, regardless of the severity of his or her offense (i.e., they can be guilty of nothing more than a minor traffic offense), can be subjected to a strip search by police or jail officials without reasonable suspicion that the arrestee is carrying a weapon or contraband.

As technology advances, police searches are becoming more invasive on a cellular level, as well, withpassive alcohol sensors,DNA collection roadblocks,iris scansandfacial recognition softwareto name just a few methodsused to assault our bodily integrity.

Americas founders could scarcely have imagined a world in which we needed protection against widespread government breaches of our privacy, including on a cellular level.

Yet thats exactly what we so desperately need.

Unfortunately, as I make clear in my bookBattlefield America: The War on the American People, the indignities being heaped upon us by the architects and agents of the American police statewhether or not weve done anything wrongare just a foretaste of what is to come.

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Fourth Amendment Freedoms are Being Choked, Guilty until Proven Innocent - Center for Research on Globalization

COA: Officer’s stop of car for expired plate ‘reasonable’ – Indiana Lawyer

An Indianapolis police officer who initiated a traffic stop that led to the arrest of a passenger in the stopped vehicle did not violate the mans constitutional rights, the Indiana Court of Appeals ruled Thursday, because the officer reasonably believed the vehicle had an expired license plate and registration.

While running license plates as part of a traffic patrol on Oct. 21, 2015, Indianapolis Metropolitan Police Department Officer Cameron Taylor ran a plate on a vehicle that showed the registration was expired. The information also showed the plate and registration had an expiration date of the same day, Oct. 21, 2015.

Taylor initiated a traffic stop because of the expired registration and asked the driver for her license and the vehicles registration. Taylor also asked the front passenger, Kevin Dowdy, if he wouldnt mind giving (him) his identification, and Dowdy complied.

Taylor then ran Dowdys information and discovered warrants for his arrest. A subsequent search revealed a receipt with pills in it in Dowdys pocket, so he was charged with possession of a narcotic drug as a Level 6 felony.

Dowdy moved to suppress evidence, arguing the stop, detention, arrest and seizure of the contraband was illegal. But the Marion Superior Court denied that motion, finding Taylor reasonably relied upon information from the Bureau of Motor Vehicles that listed the registration status as expired.

In an interlocutory appeal in Kevin Dowdy v. State of Indiana, 49A02-1612-CR-2679, Dowdy argued the denial of his motion to suppress was erroneous because his registration was valid until midnight on Oct. 21, 2015, the same day Taylor initiated the traffic stop and arrested him. He also claimed his rights under the Fourth Amendment and Article 1, Section 11 of the Indiana Constitution were violated.

But in a Thursday opinion, Indiana Court of Appeals Judge Elaine Brown wrote even if Taylor had mistakenly believed the license plate and registration had expired, the stop of the vehicle was still based upon a good faith, reasonable belief that a statutory infraction had occurred. Thus, under the totality of the circumstances, there was a particularized and objective basis for the stop, so it was not a violation of Dowdys Fourth Amendment rights, Brown wrote.

Further, Taylor did not violate the Fourth Amendment when he asked Dowdy for his identification, Brown noted, pointing to the case of Starr v. State, 928 N.E.2d 876, 878 (Ind. Ct. App. 2010). In that case, the appellate court noted that, Certainly, a police officer is free to request identification without implicating the Fourth Amendment.

Finally, using the three-part test laid out in Litchfield v. State, 824 N.E.2d 356, 361 (Ind. 2005), the appellate court determined the stop did not violate Dowdys rights under Article 1, Section 11 of the Indiana Constitution.

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COA: Officer's stop of car for expired plate 'reasonable' - Indiana Lawyer