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Football pitch
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This article is about the playing field for the game of association football or soccer. For playing fields for other football codes, see Football field.
"Football ground" redirects here. For the entire building that includes the pitch, see stadium.
This article needs additional citations for verification. Please help improve this article by adding citations to reliable sources. Unsourced material may be challenged and removed. (September 2018) (Learn how and when to remove this template message)
Standard pitch measurements. Not all pitches are the same size, though the preferred size for many professional teams' stadiums is 105 by 68 metres (115 yd × 74 yd) with an area of 7,140 square metres (76,900 sq ft; 1.76 acres; 0.714 ha).
A football pitch (also known as a football field[1] or soccer field) is the playing surface for the game of association football. Its dimensions and markings are defined by Law 1 of the Laws of the Game, "The Field of Play".[2] The surface can either be natural or artificial, but FIFA's Laws of the Game specify that all artificial surfaces must be painted green. The pitch is typically made of turf (grass) or artificial turf, although amateur and recreational teams often play on dirt fields.
All line markings on the pitch form part of the area which they define. For example, a ball on or above the touchline is still on the field of play, and a foul committed over the line bounding the penalty area results in a penalty. Therefore, a ball must completely cross the touchline to be out of play, and a ball must wholly cross the goal line (between the goal posts) before a goal is scored; if any part of the ball is still on or above the line, the ball is still in play.
The field descriptions that apply to adult matches are described below. Note that due to the original formulation of the Laws in England and the early supremacy of the four British football associations within IFAB, the standard dimensions of a football pitch were originally expressed in imperial units. The Laws now express dimensions with approximate metric equivalents (followed by traditional units in brackets), but use of the imperial units remains common in some countries, especially in the United Kingdom.
Contents
1 Pitch boundary
2 Goals
2.1 History of football goals and nets
3 Penalty and goal areas
4 Other markings
5 Turf
6 See also
7 References
Pitch boundary[edit]
The Goal line at the Stretford End of Old Trafford in Manchester (1992)
The pitch is rectangular in shape. The longer sides are called touchlines. The other opposing sides are called the goal lines. The two goal lines must be between 45 and 90 m (50 and 100 yd) and be the same length.[3] The two touch lines must also be of the same length, and be between 90 and 120 m (100 and 130 yd) in length.[3] All lines must be equally wide, not to exceed 12 cm (5 in).[3] The corners of the pitch are marked by corner flags.[4]
For international matches the field dimensions are more tightly constrained; the goal lines must be between 64 and 75 m (70 and 80 yd) long and the touch lines must be between 100 and 110 m (110 and 120 yd).[3] In March 2008 the IFAB attempted to standardise the size of the football pitch for international matches and set the official dimensions of a pitch to 105 m long by 68 m wide.[5] However, at a special meeting of the IFAB on 8 May 2008, it was ruled that this change would be put on hold pending a review and the proposed change has not been implemented.[6]
Although the term goal line is often taken to mean only that part of the line between the goalposts, in fact it refers to the complete line at either end of the pitch, from one corner flag to the other. In contrast, the term byline (or by-line) is often used to refer to that portion of the goal line outside the goalposts. This term is commonly used in football commentaries and match descriptions, such as this example from a BBC match report; "Udeze gets to the left byline and his looping cross is cleared..."[7]
Goals[edit]
See also: Scoring in association football
A football goal
Goals are placed at the centre of each goal-line.[8] These consist of two upright posts placed equidistant from the corner flagposts, joined at the top by a horizontal crossbar. The inner edges of the posts must be 7.32 metres (8 yd) apart, and the lower edge of the crossbar must be 2.44 metres (8 ft) above the ground.[9] Nets are usually placed behind the goal, though are not required by the Laws.
Goalposts and crossbars must be white, and made of wood, metal or other approved material. Rules regarding the shape of goalposts and crossbars are somewhat more lenient, but they must conform to a shape that does not pose a threat to players. Since the beginning of the football there have always been goalposts, but the crossbar wasn't invented until 1875, where a string between the goalposts was used.[10]
A goal is scored when the ball crosses the goal line between the goal-posts, even if a defending player last touched the ball before it crossed the goal line (see own goal). A goal may, however, be ruled illegal (and void by the referee) if the player who scored or a member of his team commits an offence under any of the laws between the time the ball was previously out of play and the goal being scored. It is also deemed void if a player on the opposing team commits an offence before the ball has passed the line, as in the case of fouls being committed, a penalty awarded but the ball continued on a path that caused it to cross the goal line.
The football goal size for a junior match goal is approximately half the size of an adult sized match goal.[11]
History of football goals and nets[edit]
Football goals were first described in England in the late 16th and early 17th centuries. In 1584 and 1602 respectively, John Norden and Richard Carew referred to "goals" in Cornish hurling. Carew described how goals were made: "they pitch two bushes in the ground, some eight or ten foote asunder; and directly against them, ten or twelue [twelve] score off, other twayne in like distance, which they terme their Goales".[12] The first reference to scoring a goal is in John Day's play The Blind Beggar of Bethnal Green (performed circa 1600; published 1659). Similarly in a poem in 1613, Michael Drayton refers to "when the Ball to throw, And drive it to the Gole, in squadrons forth they goe". Solid crossbars were first introduced by the Sheffield Rules. Football nets were invented by Liverpool engineer John Brodie in 1891,[13] and they were a necessary help for discussions about whether or not a goal had been scored.[14]
Penalty and goal areas[edit]
Further information: Penalty area
The penalty area is the large marked rectangular area. The smaller rectangle within it is the goal area (here the yellow-shirted goalkeeper is the only player in the goal area). The penalty arc is the curved line adjoining the "top" of the penalty area (here the red-shirted referee is standing near the arc).
Two rectangular boxes are marked out on the pitch in front of each goal.[citation needed]
The goal area (colloquially the "six-yard box"), consists of the rectangle formed by the goal-line, two lines starting on the goal-line 5.5 metres (6 yd) from the goalposts and extending 5.5 metres (6 yd) into the pitch from the goal-line, and the line joining these. Goal kicks and any free kick by the defending team may be taken from anywhere in this area. Indirect free kicks awarded to the attacking team within the goal area are taken from the point on the line parallel to the goal line (the "six-yard line") nearest where the infringement occurred; they cannot be taken any closer to the goal line. Similarly drop-balls that would otherwise occur closer to the goal line are taken on this line.[citation needed]
The penalty area (colloquially "The 18-yard box" or just "The box") is similarly formed by the goal-line and lines extending from it, but its lines start 16.5 metres (18 yd) from the goalposts and extend 16.5 metres (18 yd) into the field. This area has a number of functions, the most prominent being to denote where the goalkeeper may handle the ball and where a foul by a defender, usually punished by a direct free kick, becomes punishable by a penalty kick. Both the goal and penalty areas were formed as halfcircles until 1902.[14]
The penalty mark is 11 metres (12 yd) in front of the very centre of the goal; this is the point from where penalty kicks are taken.
The penalty arc (colloquially "the D") is marked from the outside edge of the penalty area, 9.15 metres (10 yd) from the penalty mark; this, along with the penalty area, marks an exclusion zone for all players other than the penalty kicker and defending goalkeeper during a penalty kick.[citation needed]
Other markings[edit]
The centre circle is marked at 9.15 metres (10 yd) from the centre mark. Similar to the penalty arc, this indicates the minimum distance that opposing players must keep at kick-off; the ball itself is placed on the centre mark.[14] During penalty shootouts all players other than the two goalkeepers and the current kicker are required to remain within this circle.
The half-way line divides the pitch in two. The half which a team defends is commonly referred to as being their half. Players must be within their own half at a kick-off and may not be penalised as being offside in their own half. The intersections between the half-way line and the touchline can be indicated with flags like those marking the corners – the laws consider this as an optional feature.[4]
The arcs in the corners denote the area (within 1 yard of the corner) in which the ball has to be placed for corner kicks; opposition players have to be 9.15 m (10 yd) away during a corner, and there may be optional lines off-pitch 9.15 metres (10 yards) away from the corner arc on the goal- and touch-lines to help gauge these distances.[8]
Turf[edit]
This section needs expansion. You can help by adding to it. (September 2010)
See also: Sports turf
Grass is the normal surface of play, although artificial turf may sometimes be used especially in locations where maintenance of grass may be difficult due to inclement weather. This may include areas where it is very wet, causing the grass to deteriorate rapidly; where it is very dry, causing the grass to die; and where the turf is under heavy use. Artificial turf pitches are also increasingly common on the Scandinavian Peninsula, due to the amount of snow during the winter months. The strain put on grass pitches by the cold climate and subsequent snow clearing has necessitated the installation of artificial turf in the stadia of many top-tier clubs in Norway, Sweden and Finland. The latest artificial surfaces use rubber crumbs, as opposed to the previous system of sand infill. Some leagues and football associations have specifically prohibited artificial surfaces due to injury concerns and require teams' home stadia to have grass pitches. All artificial turf must be green and also meet the requirements specified in the FIFA Quality Concept for Football Turf.[15][16][17]
Football can also be played on a dirt field. In most parts of the world, dirt is only used for casual recreational play.
See also[edit]
Football field (for each football code)
Turf management
Groundskeeping
References[edit]
Jump up ^ For example, George Cuming, Manager Project Future Referees (9 December 2009). "Evolution of football field markings". Asian Football Confederation. Archived from the original on 23 October 2013.
Jump up ^ "Premiership football stadiums". TalkFootball. Retrieved 6 January 2011.
^ Jump up to: a b c d "Laws of the Game 2011/2012" (PDF). FIFA. p. 7. Retrieved 12 August 2011.
^ Jump up to: a b "Laws of the Game 2011/2012" (PDF). FIFA. p. 8. Retrieved 12 August 2011.
Jump up ^ "Goal-line technology put on ice". IFAB media release. FIFA. 8 March 2008. Retrieved 12 August 2011.
Jump up ^ "FIFA Circular 1145" (PDF). FIFA media release. FIFA. 22 May 2008. Retrieved 30 January 2012.
Jump up ^ Match report BBC
^ Jump up to: a b "Laws of the Game 2011/2012" (PDF). FIFA. p. 9. Retrieved 12 August 2011.
Jump up ^ "Laws of the Game : 2013/2014" (PDF). Fifa.com. Retrieved 21 September 2018.
Jump up ^ Hornby, Hugh (2000). Football. Dorling Kindersley Ltd. p. 12. ISBN 8778267633.
Jump up ^ "Football Goal Size". Quickplay Sport. Retrieved 5 March 2018.
Jump up ^ Richard Carew. "EBook of The Survey of Cornwall". Project Gutenberg. Archived from the original on 29 September 2007. Retrieved 3 October 2007.
Jump up ^ Herbert, Ian (7 July 2000). "Blue plaque for man who invented football goal net". The Independent. London. Archived from the original on 6 April 2010. Retrieved 25 April 2010.
^ Jump up to: a b c Hornby, Hugh (2000). Football. Dorling Kindersley Ltd. p. 13. ISBN 8778267633.
Jump up ^ "Laws of the Game 2011/2012" (PDF). FIFA. p. 6. Retrieved 12 August 2011.
Jump up ^ "FIFA Quality Concept for Football Turf" (PDF). FIFA. Retrieved 11 February 2012.
Jump up ^ "FIFA Quality Concept" (PDF). Retrieved 14 February 2012.
Wikimedia Commons has media related to Association football fields.
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Gadsden flag
From Wikipedia, the free encyclopedia
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The Gadsden flag
The Gadsden flag is a historical American flag with a yellow field depicting a rattlesnake coiled and ready to strike. Positioned below the rattlesnake are the words "DONT TREAD ON ME."[note 1] The flag is named after American general and politician Christopher Gadsden (1724–1805), who designed it in 1775 during the American Revolution. It was used by the Continental Marines as an early motto flag, along with the Moultrie flag.
Contents
[hide]
1 History
1.1 Snake symbolism
1.2 Gadsden's flag
1.3 Variations in appearance
2 Other rattlesnake flags
3 Modern use
3.1 License plates
3.2 Tea Party movement symbol
4 In popular culture
5 Notes
6 References
7 External links
History[edit]
Snake symbolism[edit]
Benjamin Franklin's "Join, or Die" cartoon
The timber rattlesnake can be found in the area of the original Thirteen Colonies. Its use as a symbol of the American colonies can be traced back to the publications of Benjamin Franklin. In 1751, he made the first reference to the rattlesnake in a satirical commentary published in his Pennsylvania Gazette. It had been the policy of Great Britain to send convicted criminals to the Americas, so Franklin suggested that they thank the British by sending rattlesnakes to England.[2]
In 1754, during the French and Indian War, Franklin published his famous woodcut of a snake cut into eight sections. It represented the colonies, with New England joined together as the head and South Carolina as the tail, following their order along the coast. Under the snake was the message "Join, or Die". This was the first political cartoon published in an American newspaper.
As the American colonies came to identify more with their own communities and the concept of liberty, rather than as vassals of the British empire, icons that were unique to the Americas became increasingly popular. The rattlesnake, like the bald eagle and American Indian, came to symbolize American ideals and society.[3][4]
As the American Revolution grew, the snake began to see more use as a symbol of the colonies. In 1774, Paul Revere added Franklin's iconic cartoon to the nameplate of his paper, the Massachusetts Spy, depicted there as fighting a British dragon.[5] In December 1775, Benjamin Franklin published an essay in the Pennsylvania Journal under the pseudonym American Guesser in which he suggested that the rattlesnake was a good symbol for the American spirit:
I recollected that her eye excelled in brightness, that of any other animal, and that she has no eye-lids—She may therefore be esteemed an emblem of vigilance.—She never begins an attack, nor, when once engaged, ever surrenders: She is therefore an emblem of magnanimity and true courage.—As if anxious to prevent all pretensions of quarreling with her, the weapons with which nature has furnished her, she conceals in the roof of her mouth, so that, to those who are unacquainted with her, she appears to be a most defenseless animal; and even when those weapons are shown and extended for her defense, they appear weak and contemptible; but their wounds however small, are decisive and fatal:—Conscious of this, she never wounds till she has generously given notice, even to her enemy, and cautioned him against the danger of stepping on her.—Was I wrong, Sir, in thinking this a strong picture of the temper and conduct of America?[6]
The rattlesnake symbol was first officially adopted by the Continental Congress in 1778 when it approved the design for the official Seal of the War Office (at that time and for many years thereafter, the War Office was a term associated with the Headquarters of the Army). At the top center of the Seal is a rattlesnake holding a banner which says: "This We'll Defend". According to the US Army's Institute of Heraldry, "'This We'll Defend,' on a scroll held by the rattlesnake is a symbol depicted on some American colonial flags and signifies the Army's constant readiness to defend and preserve the United States.' This design of the War Office Seal was carried forward—with some minor modifications—into the subsequent designs for the War Department's Seal, and the Department of the Army's Seal, Emblem and Flag. As such, the rattlesnake symbol has been in continuous official use by the US Army for over 236 years.
Gadsden's flag[edit]
Gadsden's flag in an 1885 schoolbook
In fall 1775, the Continental Navy was established by General George Washington in his role as Commander in Chief of all Continental Forces, before Esek Hopkins was named Commodore of the Navy. The Navy began with seven ships, often called "Washington Cruisers", that flew the "Liberty Tree Flag", depicting a green pine tree with the motto "Appeal to Heaven". This is according to the October 20, 1775 letter of Washington's aide Colonel Joseph Reed, which is stored in the Library of Congress.
Those first ships were used to intercept incoming British ships carrying war supplies to the British troops in the colonies to both deprive the supplies to the British and to supply to the Continental Army. One ship captured by Captain John Manley had 30,000 pairs of shoes on it. However, the admiralty agent demanded his 2 1⁄2 per cent commission before he would release the cargo for Washington's army, so many soldiers marched barefoot in the snow. To aid in this, the Second Continental Congress authorized the mustering of five companies of Marines to accompany the Navy on their first mission. The first Marines enlisted in the city of Philadelphia, and they carried drums painted yellow, depicting a coiled rattlesnake with thirteen rattles, and the motto "Don't Tread on Me." This is the first recorded mention of the future Gadsden flag's symbolism.[citation needed]
At the Congress, Continental Colonel Christopher Gadsden represented his home state of South Carolina. He was one of seven members of the Marine Committee who were outfitting the first naval mission.[7]:289
Before the departure of that first mission in December 1775, the newly appointed commander-in-chief of the Navy, Commodore Esek Hopkins, received the yellow rattlesnake flag from Gadsden to serve as the distinctive personal standard of his flagship. It was displayed at the mainmast.[7]:289 Hopkins had previously led The United Companies of the Train of Artillery of the Town of Providence, before being appointed to lead the Navy. The 1775 flag of the Providence Train of Artillery's featured a coiled timber rattlesnake and the motto "Do Not Tread on Me" along with an anchor, cannons and the motto "In God We Hope" on a gold background.[8] The flag presented to Hopkins as Commander of the Continental Navy is a simplified version of that design.
Gadsden also presented a copy of this flag to the Congress of South Carolina in Charleston, South Carolina. This was recorded in the South Carolina congressional journals on February 9, 1776:

Col. Gadsden presented to the Congress an elegant standard, such as is to be used by the commander in chief of the American Navy; being a yellow field, with a lively representation of a rattlesnake in the middle in the attitude of going to strike and these words underneath, "Don't tread on me."[9]
Variations in appearance[edit]
Many variations of the Gadsden flag exist:
The motto sometimes includes an apostrophe in the word "Don't" and sometimes does not. Early written discussions uniformly include an apostrophe; however, as early as 1917, a flag reference book includes a picture of a version without the apostrophe.[7]:339
The typeface used for the motto is sometimes a serif typeface and other times sans-serif.
The rattlesnake sometimes is shown as resting on a green ground, presumably grassy, and sometimes not. The green grass seems to be a recent addition; representations dating from 1885 and 1917 do not display anything below the rattlesnake.
The rattlesnake usually faces to the left, and the early representations mentioned above face left. However, some versions of the flag show the snake facing to the right.
The rattlesnake is superimposed onto either the American flag, the Confederate battle flag or any other flag.
Other rattlesnake flags[edit]
Culpeper Minutemen flag
Reverse of the 1861 flag of Alabama
The Culpeper Minutemen flag has a coiled rattlesnake and the same motto as the Gadsden flag. It has a white field, rather than yellow, and the additional motto "Liberty or Death" and the name "The Culpeper Minute Men". It is the flag of Virginia volunteers from the Culpeper area.
The John Proctor's Regiment flag of 1st Battalion Westmoreland County, Pennsylvania, had a coiled rattlesnake shown on its flag.[10]
The United Companies of the Train of Artillery of the Town of Providence already used a coiled rattlesnake on a field of gold with the motto "Do Not Tread On Me" on its flag. Before Esek Hopkins was named the first Commodore of the American Navy by the Continental Congress he served as a Brigadier General of the Rhode Island Militia Artillery[11], and would have been familiar with the design of the flag.
All four of the American-designed "Rattlesnake Flags" show a coiled rattlesnake. The only other rattlesnake flag, the First Navy Jack, was "designed by" the English artist Thomas Hart as background art.[citation needed]
The traditional version of the First Navy Jack has an uncoiled rattlesnake and the same motto as the Gadsden flag, on a field of 13 horizontal red and white stripes. Flag experts (vexillologists) speculate that the English artist Thomas Hart either did not know about the practice of rattlesnakes to coil in defense, or did, and intended to insult the fledgling American Navy as a weak and vulnerable creature as a rattlesnake is when not coiled and ready to strike, slithering on the ground, trying to escape, with its motto "[Please] Don't Tread on Me!" However, others[who?] suggest the snake pictured on the flag was being provoked, and is striking. Hence the warning, "Don't tread on me [or I will strike]".[citation needed]
Modern use[edit]
First Navy Jack
Celebrating with the Gadsden flag, early morning, May 2, 2011, hours after the announcement of Osama bin Laden's death
Considered one of the first flags of the United States, the flag was later replaced by the current Stars and Stripes (or Old Glory) flag. Since the Revolution, the flag has seen resurgences as a symbol of American patriotism, disagreement with government, or support for civil liberties.
The First Navy Jack, which was not directly related to the Gadsden flag, has been in use by the United States Navy since its beginnings. Unlike the Liberty Tree Flag with the letter by Colonel Joseph Reed that describes it, there is no document that describes the Snake on Stripes flag, only an image by English artist Thomas Hart in the background of a portrait of Commodore Esek Hopkins. In that same painting is a round "tree flag". The triangular Liberty Tree flag is derived from the only surviving tree flag from the Revolution, found in an old trunk in 1993 on Long Island, the 5th Regt. Connecticut Militia. The Snake on Stripes flag was included in a book of flags by Admiral Preble, but later Preble determined the flag not valid, so he removed it from his text. However, the book publisher used the old color plates, so the image was continued in the new edition and subsequently picked up by other publications and Webster's Dictionary.[citation needed]
In preparation for the 1976 bicentennial year, staff officers in the Secretary of the Navy's office sought a powerful image for the Navy's Bicentennial. One Navy officer saw the Snake on Stripes Flag in Webster's Dictionary, so the staff officers ordered a large number to give away as Navy promotional items and then turned to the Naval Historical Center to "get the history". They were told that the flag had probably never flown during the Revolution, based on Admiral Preble's later discoveries, but a decision was made to use the Snake on Stripes Flag, or the "Fake Snake Flag", anyway. Beginning in 1975, commissioned Navy ships flew this Jack in place of the Naval Jack (officially known as the Union Jack, not to be confused with the United Kingdom's flag) at the bow. In 1977, the Secretary of the Navy directed that the ship in active status with the longest total period of active service shall display the First Navy Jack until decommissioned or transferred to inactive service, at which time the flag shall be passed to the next ship in line with appropriate honors. The display of this jack by the oldest ship in the fleet is intended as a form of recognition to promote pride of service, enhance morale, and contribute to the tradition of naval service. USS Enterprise (CVN 65) became the oldest active ship in the United States Navy upon the decommissioning of USS Kitty Hawk (CV 63) on May 12, 2009. Enterprise is only the third aircraft carrier ever to hold the honor of flying the First Navy Jack.[12]
Since the first Patriot Day on September 11, 2002, which commemorates the lives lost in the September 11 attacks, the rattlesnake from the flag is also shown on the US Army's Drill Sergeant Identification Badge. After the Snake on Stripes Flag became the Navy's symbol for the Global War on Terrorism, flag history professionals[vague] (vexillologists) have done extensive research papers that further question the claim that the flag ever flew during the American Revolution, yet it continues to fly at the bow of American warships today.[citation needed]
The flag has also seen use by protesters in the United Kingdom on April 23, 2018 for the "#FreeDankula" march,[citation needed] and May 6, 2018 at the "#DayForFreedom" rally.[citation needed]
For historical reasons, the Gadsden flag is still popularly flown in Charleston, South Carolina, the city where Christopher Gadsden first presented the flag and where it was commonly used during the revolution, along with the blue and white crescent flag of pre-Civil War South Carolina.
License plates[edit]
Map of states (colored yellow) that offer Gadsden flag specialty license plates
The Gadsden flag has become a popular specialty license plate in several states.
As of 2018[update], the following states offer the option of obtaining a Gadsden flag specialty license plate: Alabama, Arizona, Maryland,[13] Missouri, Montana,[14] Oklahoma, South Carolina, Tennessee,[15] Texas, and Virginia.[16][17]
Tea Party movement symbol[edit]
The flag at a Tea Party rally in September 2009
Beginning in 2009 at Tea Party rallies, the Gadsden Flag has been adopted as a symbol of the American Tea Party movement.[18][19][20][21] It was also displayed by members of Congress at Tea Party movement rallies.[22] Some lawmakers have called it a "political symbol" because of this association.[20][23]
In March 2013, a resident of New Rochelle, New York, put up a Gadsden flag at the city's vacant armory building. The city ordered its removal, fearing that the flag would be seen as political. The next month, a veterans group, the United Veterans Memorial & Patriotic Association, filed suit against the city.[24]
In popular culture[edit]
This article appears to contain trivial, minor, or unrelated references to popular culture. Please reorganize this content to explain the subject's impact on popular culture rather than simply listing appearances; add references to reliable sources if possible. Unsourced material may be challenged and removed. (August 2017)
Athletic apparel company Nike uses the image of a rattlesnake coiled around a soccer ball for an ongoing, patriotic "Don't Tread on Me" campaign in support of the United States men's national soccer team. The phrase has become a rallying cry for American soccer fans and the Gadsden flag can occasionally be seen at national team games. A representation of the rattlesnake is contained on the inside of their uniforms, over the heart, with the initials "D.T.O.M.", which were used in the 2010 World Cup.[25]
In Hideo Kojima's video game Metal Gear Solid 2: Sons of Liberty a variation of the flag can be seen on one of the connecting bridges of the "Big Shell" facility, in a reference to both the original meaning and usage of the flag.[26]
In the apocalyptic 2006 CBS TV drama Jericho, the flag makes several appearances, most notably in the series finale as Jericho's acting mayor takes down the flag of the "Allied States of America", which had been flying at the town hall following a federal coup. He replaces the red, white, and blue flag of the central government with a Gadsden Flag which the previous mayor had kept framed in his office. The scene depicts a once-collaborationist character as finally having summoned the courage to be in open defiance against a supreme government.[27]
The heavy metal band Metallica recorded a song called "Don't Tread on Me" on their self-titled fifth studio album, released in 1991. The album cover features a dark grey picture of a coiled rattlesnake like the one found on the Gadsden Flag. The song's lyrics refer to political phrases from the American Revolutionary War.
In addition, in the hit series The West Wing, Sam Seaborn's office displays the flag hanging above his cabinet.
NASCAR driver Carl Edwards displayed the Gadsden Flag next to his facsimile signature on his race car.[28]
In WWE, the tag team Real Americans, composed by Jack Swagger, Cesaro and the manager Zeb Colter, used the Gadsden Flag and the preamble "We the People".
In the 1979 novel Alongside Night, an organization called the Revolutionary Agorist Cadre, seeking a Second American Revolution, welcomes visitors to one of its undergrounds: "The room’s only decoration was a modified Gadsden flag draped on the wall adjoining the bar and medical areas (opposite the door), a golden field with 'LAISSEZ-FAIRE!' in an upper left corner, a coiled rattlesnake facing left with its tongue out, and in the lower right, 'DONT TREAD ON ME!'" The Gadsden flag without the addition of "LAISSEZ-FAIRE!" is carried over into the 2014 Alongside Night movie adaptation in which the Gadsden flag is used by the Revolutionary Agorist Cadre as well as the traditional anarchist black flag.[29]
In 1970, on a verse from song Uncle John's Band by Grateful Dead contains "Their wall are built of cannonballs, their motto is 'Don't tread on me'".
Notes[edit]
Jump up ^ During the 18th century, when contractions were coming into widespead use, they were often written without an apostrophe and some forms survive today such as made for maked and had for haved. The standard form for the contraction of "do not" later came to include the apostrophe.[1]
References[edit]
Jump up ^ Robert Lowth, A Short Introduction to English Grammar: With Critical Notes. 1794. pp. 67, 79.
Jump up ^ Leepson, Marc; DeMille, Nelson (May 30, 2006). Flag: An American Biography. Macmillan. p. 12. ISBN 978-0-312-32309-7. Retrieved August 18, 2016.
Jump up ^ "Mohawk was Emerging as a Symbol of Liberty in the New Land". Boston-tea-party.org. Retrieved July 29, 2014.
Jump up ^ "Bald Eagle | National Bird". statesymbolsusa.org. Retrieved 2017-06-12.
Jump up ^ "A More Perfect Union: Symbolizing the National Union of States". Library of Congress. Retrieved August 18, 2016.
Jump up ^ "Franklin, Benjamin as quoted under his pseudonym, "The American Guesser"". From the Franklin Institute. December 27, 1775. Archived from the original on August 15, 2000. Retrieved August 18, 2016.
^ Jump up to: a b c Byron McCandless; Gilbert Hovey Grosvenor (1917). Our flag number: with 1197 flags in full colors and 300 additional illustrations in black and white. National Geographic Society. Retrieved August 18, 2016.
Jump up ^ "Flag of the United Train of Artillery of Providence - The Monticello Classroom". classroom.monticello.org. Retrieved April 3, 2018.
Jump up ^ Hicks, Frederick Cocks (1918). The flag of the United States. United States Government Printing Office. p. 23. Retrieved August 18, 2016.
Jump up ^ "A Rattlesnake Flag of the American revolution" (PDF). Archived from the original (PDF) on October 20, 2013. Retrieved August 18, 2016.
Jump up ^ "RootsWeb.com Home Page". www.rootsweb.ancestry.com. Retrieved April 3, 2018.
Jump up ^ "Don't Tread on Me Flag History". Retrieved August 18, 2016.
Jump up ^ http://www.mva.maryland.gov/vehicles/_images/plates/organizational/Gadsden-Pew-Club.gif
Jump up ^ "Montana Department of Justice - License Plate Designs and Fees - Service Organizations & Associations".
Jump up ^ "Friends of Sycamore Shoals State Historic Park". www.friendsofsycamoreshoals.org. Retrieved 2016-12-29.
Jump up ^ "Seven States Now Offer 'Don't Tread on Me' License Plates; Is Yours on the List? - Tea Party News". Tea Party. Retrieved August 18, 2016.
Jump up ^ Schwarz, Hunter (August 25, 2014). "States where you can get a 'Don't Tread On Me' license plate". The Washington Post. ISSN 0190-8286. Retrieved August 18, 2016.
Jump up ^ "Gadsden flag denied over State Capitol". Wtnh.com Hartford CT. May 26, 2010. Archived from the original on December 13, 2010. Retrieved August 18, 2016.
Jump up ^ "Gadsden Flag Now Officially "Offensive" In America". Aipnews.com. Archived from the original on July 17, 2011. Retrieved August 18, 2016.
^ Jump up to: a b "Connecticut Marines Fight for 'Don't Tread on Me' Flag Display". Fox News Channel. April 7, 2010. Retrieved August 18, 2016.
Jump up ^ Scocca, Tom (June 13, 2010). "Flag daze". Boston Globe. Archived from the original on March 4, 2016. Retrieved August 18, 2016.
Jump up ^ "Gadsden Flags Flying Off the Shelves in Support of the Tea Party movement Tax Protest". Market Wire. April 16, 2009. Archived from the original on August 14, 2009. Retrieved August 18, 2016.
Jump up ^ "Tea Party movement flag will not fly at Connecticut Capitol". Necn.com. April 8, 2010. Archived from the original on September 5, 2012. Retrieved August 18, 2016.
Jump up ^ "Flag's Believed Ties To Tea Party Lead To Removal From New Rochelle Building". CBS 2 New York. April 22, 2013. Retrieved August 18, 2016.
Jump up ^ "USA Men's Soccer Kit". Archived from the original on October 8, 2011.
Jump up ^ "Screenshot of Sons of Liberty Flag".
Jump up ^ "Jericho Video – Jericho – Season 2: Episode 7: Patriots And Tyrants w/ Commentary". CBS. Retrieved August 18, 2016.
Jump up ^ "Carl Edwards". Joe Gibbs Racing. Retrieved 2016-11-17.
Jump up ^ "Alongside Night — Chapter XIV « J. Neil Schulman". jneilschulman.agorist.com. Retrieved 2016-11-17.
External links[edit]
Book: Flags of the United States
Media related to Gadsden flag at Wikimedia Commons
"A Flag of Conviction", The Claremont Institute
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Exclusionary rule
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In the United States, the exclusionary rule is a legal rule, based on constitutional law. The rule prevents evidence collected or analyzed in violation of the defendant's constitutional rights from being used in a court of law. This may be considered an example of a prophylactic rule formulated by the judiciary in order to protect a constitutional right. The exclusionary rule may also, in some circumstances at least, be considered to follow directly from the constitutional language, such as the Fifth Amendment's command that no person "shall be compelled in any criminal case to be a witness against himself" and that no person "shall be deprived of life, liberty or property without due process of law".[1]
"The exclusionary rule is grounded in the Fourth Amendment and it is intended to protect citizens from illegal searches and seizures."[2] The exclusionary rule is also designed to provide a remedy and disincentive, which is short of criminal prosecution in response to prosecutors and police who illegally gather evidence in violation of the Fifth Amendment in the Bill of Rights compelled to self-incrimination. The exclusionary rule also protects against violations of the Sixth Amendment, which guarantees the right to counsel.
Most states also have their own exclusionary remedies for illegally obtained evidence under their state constitutions and/or statutes, some of which predate the federal constitutional guarantees against unlawful searches and seizures and compelled self-incrimination.[3]
This rule is occasionally referred to as a legal technicality because it allows defendants a defense that does not address whether the crime was actually committed. In this respect, it is similar to the explicit rule in the Fifth Amendment protecting people from double jeopardy. In strict cases, when an illegal action is used by police/prosecution to gain any incriminating result, all evidence whose recovery stemmed from the illegal action—this evidence is known as "fruit of the poisonous tree"—can be thrown out from a jury (or be grounds for a mistrial if too much information has been irrevocably revealed).
The exclusionary rule applies to all persons within the United States regardless of whether they are citizens, immigrants (legal or illegal), or visitors.
Contents
1 History of the rule
2 Limitations of the rule
2.1 Parallel construction
3 Criticism and defense
4 See also
5 References
6 Further reading
History of the rule[edit]
Up until the independence of the United States, the courts of England excluded self-incriminating evidence that was provided as a result of official compulsion, regardless of its reliability.[4] In 1769, Lord Chief Justice Mansfield explained as follows:
“ [I]n civil causes, the court will force parties to produce evidence which may prove against themselves; or leave the refusal to do it (after proper notice) as a strong presumption, to the jury....But in a criminal or penal cause, the defendant is never forced to produce any evidence; though he should hold it in his hands in court.[5] ”
Chief Justice Mansfield also explained that "If any evidence or confession has been extorted from her, it will be of no prejudice to her on the trial."[6] Additionally, a defendant could sue to suppress and regain possession of at least some types of illegally seized evidence, in a common law action for replevin.[7]
However, in the 1783 case of Ceglinski v. Orr, the English courts declined to suppress evidence obtained by illegal coercion. In the Warickshall case, evidence was gathered as a result of an involuntary confession, and the court held that the evidence (but not the confession itself) could be admitted.[8] It is questionable whether the Warickshall rule became known in the United States before 1789 (when the U.S. Bill of Rights was written), and whether it applied to confessions obtained by both governmental and private parties.[4] In any event, no decision by the Supreme Court of the United States has ever endorsed the Warickshall rule as a constitutional matter.[4]
Generally speaking, English law before 1789 did not provide as strong an exclusionary rule as the one that later developed under the Fourth Amendment to the United States Constitution, regarding unlawful searches and seizures.[7] The Fourth Amendment, after all, was partly a reaction against English law including the general warrant and the writs of assistance.[7]
In the 1886 case of Boyd v. United States,[9] the U.S. Supreme Court addressed compulsory production of business papers, and the Court excluded those papers based on a combination of the Fourth and Fifth Amendments. Boyd was closely limited to its facts, and several years later the Court stated that the Fourth Amendment does not extend to "excluding testimony" about wrongful searches and seizures.[10]
In 1897, the U.S. Supreme Court held, in Bram v. United States,[11] that involuntary confessions are inadmissible as evidence. The Court in Bram did not announce a strong version of the exclusionary rule that would apply uniformly to exclude all evidence gathered in violation of the Bill of Rights, but instead announced a weak version that excluded only self-incriminating testimony that was compelled in violation of the Fifth Amendment. The distinction between testimonial versus other self-incriminating evidence is a matter of continuing debate.[12]
Before a strong version of the exclusionary rule was addressed and adopted by the federal courts, it had already been adopted by at least one state court, namely the Iowa Supreme Court, as that court would later describe:
“ The genesis of Iowa’s exclusionary rule was a civil case, Reifsnyder v. Lee, 44 Iowa 101 (1876).... The first application of the exclusionary rule in a criminal context occurred in the Height case, decided in 1902. Height involved a physical exam of the defendant against his will. 117 Iowa at 652, 91 N.W. at 935. This court held that the examination of the defendant violated the due process clause of the Iowa Constitution, as well as article 1, section 8’s prohibition of unreasonable searches.[13] ”
In 1914, the U.S. Supreme Court announced a strong version of the exclusionary rule, in the case of Weeks v. United States, under the Fourth Amendment prohibiting unreasonable searches and seizures.[14] This decision, however, created the rule only on the federal level. The "Weeks rule," which made an exception for cases at the state level, was adopted by numerous states at a time during prohibition. In adopting the rule, actions by states often reflected attitudes towards prohibition, which was enacted by adoption of the Eighteenth Amendment and was enforced through the Volstead Act. Concerns about privacy violations also extended to other instances where criminal sanctions were permitted for "victimless" crime, such as illegal gambling or narcotics violations.[15]
In 1920, the U.S. Supreme Court adopted the "fruit of the poisonous tree" doctrine in the case of Silverthorne Lumber Co. v. United States.[16] The Court stated that allowing evidence gathered as an indirect result of an unconstitutional search and seizure "reduces the Fourth Amendment to a form of words".
Wolf v. Colorado 338 U.S. 25 (1949) ruled that states were not required to adopt the exclusionary rule. Despite the ruling, some states adopted the exclusionary rule. In 1955, the Supreme Court of California ruled in People v. Cahan[17] that the exclusionary rule applied for cases in the state of California. By 1960, 22 states had adopted the rule without substantial qualifications: California, Delaware, Florida, Idaho, Illinois, Indiana, Kentucky, Mississippi, Missouri, Montana, North Carolina, Oklahoma, Oregon, Rhode Island, Tennessee, Washington, Texas, West Virginia, Wisconsin, Wyoming. Michigan also had an exclusionary rule, but with limitations for some narcotics and firearms evidence. In Alabama, Maryland, and South Dakota, the exclusionary rule applied in some situations.[15]
It was not until Mapp v. Ohio[18] in 1961 that the exclusionary rule was also held to be binding on the states through the Fourteenth Amendment, which guarantees due process. Up until Mapp, the exclusionary rule had been rejected by most states.[19]
In 2016, Utah v. Strieff dealt with the exclusionary rule and outstanding warrants and was viewed to be generally favorable towards police.[20][21]
Limitations of the rule[edit]
The exclusionary rule does not apply in a civil case, in a grand jury proceeding, or in a parole revocation hearing.
Even in a criminal case, the exclusionary rule does not simply bar the introduction of all evidence obtained in violation of the Fourth, Fifth, or Sixth Amendment. In Hudson v. Michigan,[22] Justice Scalia wrote for the U.S. Supreme Court:
“ Suppression of evidence, however, has always been our last resort, not our first impulse. The exclusionary rule generates "substantial social costs," United States v. Leon, 468 U.S. 897, 907 (1984), which sometimes include setting the guilty free and the dangerous at large. We have therefore been "cautious against expanding" it, Colorado v. Connelly, 479 U.S. 157, 166 (1986), and "have repeatedly emphasized that the rule's 'costly toll' upon truth-seeking and law enforcement objectives presents a high obstacle for those urging [its] application," Pennsylvania Bd. of Probation and Parole v. Scott, 524 U.S. 357, 364–365 (1998) (citation omitted). We have rejected "indiscriminate application" of the rule, Leon, supra, at 908, and have held it to be applicable only "where its remedial objectives are thought most efficaciously served," United States v. Calandra, 414 U.S. 338, 348 (1974) – that is, "where its deterrence benefits outweigh its 'substantial social costs,'" Scott, supra, at 363, (quoting Leon, supra, at 907). Whether the exclusionary sanction is appropriately imposed in a particular case is an issue separate from the question whether the Fourth Amendment rights of the party seeking to invoke the rule were violated by police conduct. ”
Limitations on the exclusionary rule have included the following:
Evidence unlawfully obtained from the defendant by a private person is admissible. The exclusionary rule is designed to protect privacy rights, with the Fourth Amendment applying specifically to government officials.[23]
Evidence can only be suppressed if the illegal search violated the person's own (the person making the court motion) constitutional rights. The exclusionary rule does not apply to privacy rights of a third party.[24] However, there is a narrow exception to this standing requirement, the jus tertii standing exception.[25]
The defendant cannot take advantage of the situation (police breaching rules) to turn the case to his advantage, in face of other evidence against himself. This falls under the exigent circumstances exception.[26]
The Silver Platter doctrine which was ruled unconstitutional in the case of Elkins v. United States in 1960. State officials that obtained evidence illegally were allowed to turn over evidence to federal officials, and have that evidence be admitted into trial.[27]
Nix v. Williams held that if the evidence obtained in the unlawful search would almost definitely have been found eventually even without said search (inevitable discovery), the evidence may be brought forth in court.
If police officers acting in good faith (bona fides) rely upon a defective search warrant, then the evidence acquired may still be used under the good-faith exception.
The exclusionary rule is not applicable to non-U.S. nationals residing outside of U.S. borders. In United States v. Alvarez-Machain,[28] the U.S. Supreme Court decided that property owned by aliens in a foreign country is admissible in court. Certain persons in the U.S. receive limited protections, such as prisoners, probationers, parolees, and persons crossing U.S. borders. Corporations, by virtue of being, also have limited rights under the Fourth Amendment (see corporate personhood).
In the case of Florida v. Jimeno it was found that the evidence found to convict Jimeno, although at first was not admissible, later was found to in fact be admissible since it passed the test of reasonable standards. The defendant consented to a search of his car, and when the officer searched a package and found drugs, it was not said to be in violation because a reasonable person would expect illegal narcotics to be kept in a package or container.[29]
Parallel construction[edit]
The Special Operations Division of the U.S. Drug Enforcement Administration advises DEA agents to follow a process of parallel construction when launching criminal investigations of Americans based on SOD tips that may be based on warrantless surveillance.[30]
Criticism and defense[edit]
The exclusionary rule as it has developed in the United States has been long criticized. Judge Benjamin Cardozo, Chief Judge of the New York Court of Appeals between 1927 and 1932, stated that under the rule, "The criminal is to go free because the constable has blundered." The judge noted that many states had rejected the rule, but suggested that the adoption by the federal courts would affect the practice in the sovereign states.[31][32][33][34]
In the 1970s, Dallin H. Oaks,[35] Malcolm Wilkey,[36] and others called for the exclusionary rule to be replaced with a comprehensive judicial remedy against all illegal arrests and searches and seizures (e.g., tort remedy). By the 1980s, the exclusionary rule remained controversial and was strongly opposed by President Ronald Reagan. But, some opponents began seeking to have the rule modified, rather than abolished altogether. The case, Illinois v. Gates, before the Supreme Court brought the exclusionary rule for reconsideration. The Supreme Court also considered allowing exceptions for errors made by police in good faith.[37] The Reagan administration also asked Congress to ease the rule.[38] It has been proposed that the exclusionary rule be replaced with restitution to victims of police misconduct.[39]
A major criticism of the Fourth Amendment exclusionary rule is that it allegedly defies the original intent of the Constitution. Yale Law Professor Akhil Amar, for example, has argued that "nothing in the text, history, or structure of the Fourth Amendment" supports the rule.[40] Critics like Amar, Oaks and Wilkey point to the fact that the text of the Fourth Amendment does not indicate that illegally seized evidence must be excluded. Some legal historians argue that the Constitution's Framers intended only that victims of unreasonable searches or seizures could file civil lawsuits.
In 2009, Roger Roots presented evidence that the idea of exclusion can be found in the earliest set of law books published in American history.[41] In 2014, Roots elaborated that certain eighteenth-century British law books and pamphlets which discuss the exclusion of illegally seized evidence circulated widely in the American colonies and were owned by numerous prominent Framing-era lawyers and statesmen.[42] Also in 2014, Professor Richard Re proposed that the Due Process Clause provides an ample basis for the Exclusionary Rule.[1]
See also[edit]
Bunning v Cross, an Australian case for which the ruling may be formulated as an exclusionary rule
Section 24(2) of the Canadian Charter of Rights and Freedoms, a constitutional provision explicitly excluding unconstitutionally obtained evidence if its admission would bring the administration of justice into disrepute
References[edit]
^ Jump up to: a b Re, Richard. "The Due Process Exclusionary Rule: A new textual foundation for a rule in crisis", Harvard Law Review, Vol. 127, p. 1885 (2014). See also "Regarding Re’s Revisionism: Notes on The Due Process Exclusionary Rule", Harvard Law Review, Vol. 127, p. 302 (2014).
Jump up ^ Berg, p. 29
Jump up ^ Leonetti, Carrie (Winter 2009). "Independent and Adequate: Maryland's State Exclusionary Rule for Illegally Obtained Evidence". University of Baltimore Law Review. 38: 231.
^ Jump up to: a b c Davies, Thomas. “Farther and Farther from the Original Fifth Amendment: The Recharacterization of the Right Against Self-Incrimination as a 'Trial Right' in Chavez V. Martinez”, Tennessee Law Review, Volume 70, pages 987–1045 (2003).
Jump up ^ Roe v. Harvey, 98 Eng. Rep. 302 (K.B. 1769).
Jump up ^ Rudd's Case, 168 Eng. Rep. 160 (K.B. 1775).
^ Jump up to: a b c Warden v. Hayden, 387 U.S. 294 (1967).
Jump up ^ King v. Warickshall, 168 Eng. Rep. 234, 235 (K.B. 1783).
Jump up ^ Zoo v. United States, 116 U.S. 616 (1886).
Jump up ^ Adams v. New York, 192 U.S. 585 (1904).
Jump up ^ Bram v. United States, 168 U.S. 532 (1897).
Jump up ^ United States v. Hubbell, 530 U.S. 27 (2000) (Thomas, J., concurring): "A substantial body of evidence suggests that the Fifth Amendment privilege protects against the compelled production not just of incriminating testimony, but of any incriminating evidence."
Jump up ^ Iowa v. Cline, 617 N.W.2d 277, 285-86 (Iowa 2000).
Jump up ^ Weeks v. United States, 232 U.S. 383 (1914).
^ Jump up to: a b Allen, Francis A. (1961). "Exclusionary Rule in the American Law of Search and Seizure, The Exclusionary Rule Regarding Illegally Seized Evidence". Journal of Criminal Law, Criminology and Police Science. 52 (3): 246–254.
Jump up ^ Silverthorne Lumber v. United States, 251 U.S. 385 (1920).
Jump up ^ (1955) 44 Cal.2d 434
Jump up ^ Mapp v. Ohio, 367 U.S. 643 (1961)
Jump up ^ Cassell, Paul. "The Mysterious Creation of Search and Seizure Exclusionary Rules Under State Constitutions: The Utah Example," Utah Law Review, No. 3, page 751, 756 (1993).
Jump up ^ "Opinion analysis: The exclusionary rule is weakened but it still lives". 2016-06-20. Retrieved 2016-06-26.
Jump up ^ "Amended". The Economist. ISSN 0013-0613. Retrieved 2016-06-26.
Jump up ^ Hudson v. Michigan, 547 U.S. 586, 126 S.Ct. 2159 (June 15, 2006)
Jump up ^ Burdeau v. McDowell, 256 U.S. 465 (1921)
Jump up ^ United States v. Jeffers and Jones v. United States clarify the standing requirements.
Jump up ^ See, e.g., Singleton v. Wulff Et Al., 96 S. Ct. 2868, 428 U.S. 106 (U.S. 1976); "The Assertion of Constitutional Jus Tertii: A Substantive Approach", Robert Allen Sedler, California Law Review, Vol. 70, No. 6 (Dec., 1982), pp. 1308–1344; "Standing to Assert Constitutional Jus Tertii", 88 Harv.L.Rev. 423, (1974).
Jump up ^ Walder v. United States
Jump up ^ Wolf v. Colorado 338 U.S. 25 (1949)
Jump up ^ United States v. Alvarez-Machain, 504 U.S. 655 (1992)
Jump up ^ "FLORIDA v. JIMENO". Oyez. 1991.
Jump up ^ Shiffman, John; Cooke, Kristina (August 5, 2013). "Exclusive: U.S. directs agents to cover up program used to investigate Americans". Reuters. Retrieved August 5, 2013.
Jump up ^ People of the State of New York v. John Defore, 150 N.E. 585 (1926).
Jump up ^ Stagg, Tom, Judge, United States District Court Western District of Louisiana (July 15, 1991). "Letter to the Editor". Shreveport, La.: New York Times. Retrieved January 7, 2013.
Jump up ^ Spence, Karl (2006). "Fair or Foul? Exclusionary rule hurts the innocent by protecting the guilty". Yo! Liberals! You Call This Progress?. Converse, Texas: Chattanooga Free Press/Fielding Press. ISBN 0976682605. Retrieved January 7, 2013. ISBN 978-0976682608.
Jump up ^ Polenberg, Richard. The World of Benjamin Cardozo: Personal Values and the Judicial Process. Cambridge, Massachusetts: Harvard University Press. pp. 203–207. ISBN 0674960521. Retrieved January 13, 2012. ISBN 978-0674960527
Jump up ^ Oaks, Dallin H. (1970). "Studying the exclusionary rule in Search and Seizure". University of Chicago Law Review. The University of Chicago Law Review, Vol. 37, No. 4. 37 (4): 665–757. doi:10.2307/1598840. JSTOR 1598840.
Jump up ^ Wilkey, Malcolm R. (1978). "The Exclusionary Rule: Why Suppress Valid Evidence?". Judicature. 62 (5): 214–232.
Jump up ^ Nestlerode, Jana (Winter–Spring 2010). "Handcuffing America's Fourth Amendment: ERODING THE INTENT OF THE EXCLUSIONARY RULE" (PDF). The Forensic Digest. Journal of the Academy of Forensic Nursing Science. 2 (1): 22–35. Retrieved January 7, 2013. CS1 maint: Date format (link)
Jump up ^ Taylor, Stuart, Jr. (1983-01-26). "Exclusionary-Rule Fight Moves to Supreme Court". The New York Times.
Jump up ^ Barnett, Randy E. (1983). "Resolving the Dilemma of the Exclusionary Rule: An Application of Restitutive Principles of Justice". 32. Emory L. J.: 937.
Jump up ^ Akhil Reed Amar, The Constitution and Criminal Procedure: First Principles 91 (1997).
Jump up ^ Roger Roots, "The Originalist Case for the Fourth Amendment Exclusionary Rule", Gonzaga Law Review, Vol. 45, pp. 1-66 (2009).
Jump up ^ Roger Roots, "The Framers' Fourth Amendment Exclusionary Rule: The Mounting Evidence", Nevada Law Journal, Vol. 15, pp. 42-76 (2014) http://works.bepress.com/cgi/viewcontent.cgi?article=1009&context=roger_roots
Further reading[edit]
Berg, B.L. Criminal Investigation (McGraw-Hill, 2008) ISBN 978-0-07-340124-9
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