Tuesday, February 26, 2013

Rising Courthouse Violence

When a person considers the safety that they are afforded at a courthouse, they think that it is relatively secure because there are several armed police officers present at all times.  At the same time, it is difficult to ignore that going to a courthouse might be risky business by the mere fact of what occurs in a courthouse on a day-to-day basis.  It does not matter whether the case deals with traffic violations or family-law disputes, many times a judge or jury can have lasting effects on a person’s life.  It is no surprise that emotions run high regardless of what side of the issue you are advocating for.

“There has been a steady increase in courthouse shootings, bombings, and arson attacks over the last 40 years––28 incidents from 1970-79, 45 from 1980-89, 67 from 1990-99 and 88 from 2000-2009.”  Between 1990 and 2007, “there have been at least twenty-six shootings in the courthouses across the United States.”  Out of the twenty-six incidents, around half of the shootings involved family-law disputes.  More recently, between the years of 2010 and 2011, there have been an estimated 117-documented incidents of courthouse violence throughout the United States.                                          

One of the most recent examples of courthouse violence was a shooting that took place on Monday, February 11 at a Delaware courthouse.  “The shooting was a culmination of years of strife between the Matusiewicz and Belford family.”  For several years, David Matusiewicz had been fighting his ex-wife, Christine Belford, for the custody of their three daughters.  During the bitter custody battle, David kidnapped his daughters and took them to Nicaragua after he had forged his ex-wife’s signature on a loan document.  As a result, his parental rights were terminated in 2011 while he was serving a prison sentence for the kidnapping.  Although he lost custody of his daughters, Matusiewicz had a court order against him that required him to make child support payments to his wife––Matusiewicz was behind on the payments.  On the morning of February 11, both Belford and Matusiewicz were present at the courthouse to attend a child-support hearing.  However, Thomas Matusiewicz, David’s father, opened fire in the public lobby of the courthouse killing his former daughter-in-law and her friend by firing a single shot at each woman.  Immediately after, Thomas Matusiewicz exchanged fire with officers and died––although it is uncertain whether it was an officer’s bullet that killed him or a self-inflicted wound.  Two officers wearing armored vests were also injured during this incident.

Courthouse shootings are extremely deadly since the shooter typically shoots his victim from a very close range.  In twenty of the twenty-six incidents that occurred from 1990-2007, there was at least one person who died.  When incidents like this occur, the first questions to arise are:  were there proper safeguards in place?  And, could this incident have been prevented?  After incidents like this, people generally jump to the conclusion that proper safeguards were not in place.  While the details of the Delaware incident are currently under investigation, it is clear that the Delaware courthouse had several safeguards in place.  There are usually a dozen armed officers on duty who are “assisted by roaming court bailiffs and at least one police dog and handler.”  Additionally, there is a security checkpoint near the front door.  However, it is known that Thomas Matusiewicz had not yet passed “through the security perimeter located a few feet inside the front doors.”  If these safeguards were already in place, then what else could be added to protect those people in a courthouse?  The Wilmington Mayor, Dennis P. Williams, thinks that one thing that can be done in order to further safety is “pushing the security out to the entrances, making visitors enter one by one and eliminating the lobby as an area to congregate before being screened.”  This would prevent incidents from occurring inside of the courthouse.  However, others could argue that this would still leave people exposed while they are waiting to go into the courthouse.

Other jurisdictions are taking additional precautions to deter potential perpetrators of violence at courthouses.  For example in Washington state, the Legislature is reviewing whether to pass a bill which would make “misdemeanor assaults that occur in and around courthouses to be treated like felonies, regardless of the victim, and want courthouse felonies to be treated as an aggravating factor for judges to consider during sentencing.”  These stiffer penalties for violent acts in or around a courthouse are not without cause.  Two fairly recent incidents have prompted the attempt to impose stiffer penalties.  The first incident took place in March 2012 where a man stabbed and shot an officer as a courthouse and proceeded to stab a judge who attempted to aid the officer.  The second incident took place in January of this year, when a man assaulted an officer after the officer asked him to the attacker to stop intimidating witnesses.

The idea of pushing security checkpoints to the entrances of courthouses and making stiffer penalties for crimes committed in or around courthouse would work well together to lower the incidents of violence in and around courthouse.  The addition of the stiffer penalties would provide a deterrent effect that might curb some of the incidents.  However, these deterrent effects of these penalties can only go so far since people who are determined to commit a crime will not decide not to hurt someone because they might be in jail for a longer amount of time.  Other additional precautions that could be considered would be screening people prior to them entering the parking lot of the courthouse so as to prevent people carrying weapons and/or hiring more officers to work as security in courthouses.  However, these last two options could be cost prohibitive. 

Elizabeth Rivera
Blogger, Criminal Law Brief

Image courtesy of ABC News

Friday, February 22, 2013

Guilty But Innocent

In November 1992, seventeen year old Daniel Taylor was awaken out of his sleep by police and brought to the police station for questioning.  Almost three and a half hours later Daniel Taylor confessed to a double murder.  The problem here is that Daniel had an alibi, one that was later confirmed by the Assistant State Attorney.  Daniel was locked up in a jail cell on the night of the murders making it impossible for him to have committed this crime.  Yet, he was still tried and convicted.

Wrongful convictions happen and it is the epitome of injustice.  False confessions contribute to approximately twenty-five percent of all wrongful convictions.  Our criminal justice system is built on the notion that you are innocent until proven guilty.  However, once someone falsely confesses the presumption of innocence is taken away and they are not likely to get a fair trial.  There are several factors that contribute to false confessions including but not limited to: (1) contamination of the interrogation, (2) lying about evidence, (3) the length of the interrogation, and (4) using psychological methods on juveniles and cognitively impaired individuals who more impressionable and suggestible. 

The contamination of an interrogationoccurs when law enforcement officials disclose facts of the case during the interrogation.  When the interrogator has disclosed facts of the case to the suspect it makes it hard to determine whether the confession is valid or just a rehash of what the suspect learned during the interrogation.  Additionally, law enforcement officials routinely lie about false evidence to elicit confessions which can be extremely coercive and result in a false confession.  One of the reasons innocent people confess is because they believed that there was overwhelming evidence against them and confessing was the best alternative.  

Lengthy interrogations are another factor that increases the risk of false confessions.  There are several ways that a lengthy interrogation can increase these risks.  First, officers may unintentionally contaminate an interrogation due to exhaustion.  Officers, like suspects, become tired and exhausted after long hours.  Working on a lack of sleep could result in unintentional mistakes.  Furthermore, officers become frustrated when they have been questioning a suspect for several hours to no avail, this could lead to the use of improper and illegal tactics to elicit a confessions.  Additionally, suspects become exhausted making them more suggestible.  Furthermore, when a suspect is exhausted they just want to leave.  Consequently, suspects become more willing to say what the officer wants to hear in order to leave the interrogation room.  Juveniles are even more vulnerable to these factors.

The chances of eliciting a false confession increases when interrogating juveniles.  The court in Roper v. Simmonssaid that children do not have fully matured levels of judgment and are more susceptible to peer-pressure than adults.  Likewise, juveniles would be more susceptible to psychological interrogation techniques used to elicit confessions.  We have many laws in place which limit the rights of juveniles––juveniles are not allowed to vote, smoke cigarettes, or drink alcohol, nor can they get a driver’s license until they are sixteen.  As evident by these laws, we recognize the cognitive limitations of juveniles.  Juveniles are more impressionable and suggestible than adults; therefore they can be more easily coerced and more easily deceived into believing lies about evidence.

In addition to the above mentioned contributing factors, tunnel vision by police and prosecutors can also contribute to false confessions.  Tunnel vision occurs when police and prosecutors focus on one suspect early on in the investigation.  When a false confession occurs, it is hard for police and prosecutors to make sense of an innocent person confessing to a heinous crime that he did not commit.  The investigation stops or changes once a person confesses––law enforcement officials no longer investigate the crime; instead investigating the person with the goal of corroborating what was confessed to.  As a result of tunnel vision, police and prosecutors tend to put more weight to evidence that supports their theory and discount evidence that contradicts their theory.  Tunnel vision infects both the criminal investigation and post-conviction relief for the wrongfully convicted. 

False confessions are extremely difficult to overcome.  A false confession is an admission of guilt which is why false confessions are more likely to lead to wrongful convictions.  In essence, a false confession removes the presumption of innocence that criminal defendants are afforded in this country.  Furthermore, when a suspect confesses to a crime, he simply confirms what the police already believed.  Generally, after a suspect confesses the police and prosecution begin to build a case around that suspect and his confession.  The police and prosecution specifically look for evidence that coincides with what the suspect confessed, making it easy for them to overlook contradicting evidence.  We are logical beings; therefore if a person confesses to a crime with detail and we find evidence that contradicts one of his statements we will tend to believe that the contradicting evidence is wrong. 

Mr. Taylor has spent more than half of his life behind bars for a crime he did not commit.  This injustice should not have happened.  The prosecutor in Mr. Taylor’s case confirmed his alibi before his trial, yet still proceeded with the trial.  “We may never know how many innocent people are in prison.  Instead, we ask how many more will have to be exonerated through the hard science of DNA before every jurisdiction in the country enacts reforms that can prevent this injustice in the first place.”  We cannot control every factor that may contribute to a false confession; however, we can control police and prosecutorial misconduct.  We must be proactive because, as we have illustrated, it is extremely difficult to overcome the weight of a false confession. 

Tonya Davis
Blogger, Criminal Law Brief

Tuesday, February 19, 2013

A Change is Gonna Come: Continuing Reforms in Juvenile Justice Laws

Recently, lawmakers in Georgia have decided a change is needed in their juvenile justice laws.  After Georgia’s legislature passed a series of reforms in March 2012 that revised sentencing laws for non-violent drug and property offenders,[1]lawmakers have turned their attention to fixing Georgia’s increasingly expensive juvenile system.  Will these proposed changes represent a sincere shift in how states adjudicate young offenders, or, will they simply be a temporary stopgap in how Georgia handles the offenses of its youngest offenders and budgetary constraints?

Given, what Georgia lawmakers have considered an overwhelming success from their 2012 criminal justice system reforms––based on both statistics and budgetary freedom––the focus for the current session is how to minimize the financial impact of the juvenile system.[2]  Currently, Georgia has a $300 million budget for the juvenile justice department.  A large percentage of Georgia’s budget––almost two-thirds––goes to youth residential facilities, where the average cost of a bed per year is over $91,000 for long-term facilities and over $88,000 per year for short term youth detention centers.  By comparison, the incarceration of one single adult in a Georgia prison costs approximately $18,000.  Clearly, with such high prices, a recidivism rate of nearly sixty-five percent of youthful offenders incarcerated in residential facilities is nothing less than a systematic failure.[3]

Following the release of the Criminal Justice Reform Council Report on Juvenile Justice,[4]the Chief Justice of the Georgia Supreme Court called for an overhaul of the juvenile justice system.[5]  Chief Justice Carole Hunstein stated that legislators need to divert non-violent juvenile offenders away from residential facilities and create a system in which such offenders become more involved in community programs while taking a look at solutions to other common problems within the juvenile system––substance abuse, domestic relations, and gang involvement.[6]  As the Reform Council Report notes, their recommended changes would save Georgia taxpayers more than $88 million over the next five years.  Two questions remain: (1) what reforms are the legislator proposing, and (2) will it be effective in both serving the needs of offender rehabilitation while minimizing systematic cost?

In their report, the Reform Council proffered a series of fifteen recommendations, which were broken into two categories––(1) those that focused on limiting the use of residential and short term detention facilities to high-risk serious offenders, and (2) those that focused on reducing recidivism by strengthening community supervision programs.  The first category focused on the actual reformation of how the system designates youthful offenders and assesses potential penalties, whereas the second category focused on the need to “cut the fat” from increasingly unsuccessful community supervision programs that have failed to keep offenders from re-entering the justice system.

Chief among the first category’s recommendations is the creation of a two-class system within the Designated Felony Act.  Currently under Georgia law, there is a single all-encompassing felony provision that ranges from burglary to murder.  For the Reform Council, a two-class system that distinguishes the offenders by both severity of offense and risk-level would allow for a better use of state funded resources.  Similarly, the Reform Council recommended the prohibition of low-risk status offenders and misdemeanors offenders from commitment to residential or detention facilities.[7]  The report noted that in 2011, fifty-three percent of juveniles in non-secure residential facilities were adjudicated for either misdemeanors or status offenses.  Following the path of states like Texas, Florida, Virginia, and Alabama, the Reform Council recommended that that status offenders be barred entirely from being sentenced to residential or detention centers; such facilities should be reserved for those juveniles who (1) are adjudicated delinquent for a felony offense; or (2) whose current offense is a misdemeanor but has at least four prior adjudications of delinquency including at least one prior felony adjudication.  Such recommendations, if adopted, should help to curb the inflow of non-violent offenders in an increasingly expensive and inefficient system.  However, what, if any, repercussion can the state offer to those barred from out-of-home facilities (residential or detention placements)?

The second part of the Reform Council’s report addressed the limited sentencing options that juvenile judges have in lieu of out-of-home placement.[8]  However, despite a series of recommendations regarding increased reporting and auditing requirements and the implementation of new juvenile assessment tools––scales that assess the risk and placement of a juvenile––the Reform Council offered few concrete steps for legislators and community officials to follow in reforming alternative programs.  Regardless, these recommendations were drafted into House Bill 242 (“The Juvenile Justice Reform Bill”),[9]which was introduced to the Georgia General Assembly on February 8, 2013. 

It is evident from the high cost of out-of-home placement and the increasing recidivism rates that the current system juvenile justice system in Georgia is broken.  While the steps recommended by the report are a clear start to reassessing the needs of both the individual offenders and the system as a whole, there are still huge concerns with how to reduce recidivism rates.  Keeping low-risk offenders out of residential facilities is certainly a step in the right direction; however, more guidance, reform, and oversight is needed in alternative community based programs. 

Jason Navia
Senior Blog Editor, Criminal Law Brief

 Image by: Ken Lund

[1] http://www.legis.ga.gov/Legislation/20112012/127628.pdf
[2] http://jacksonville.com/news/crime/2013-01-23/story/10000-empty-beds-georgia-county-jails-due-criminal-justice-reforms
[3] Note: The overall recidivism rate of Georgia youth offenders is fifty-three percent.
[5] http://www.thecrimereport.org/news/crime-and-justice-news/2013-02-ga-jj-reform
[6] http://www.ajc.com/news/news/crime-law/push-begins-to-reform-juvenile-justice-system/nWJbt/
[7] http://jjie.org/hearings-soon-on-georgia-juvenile-justice-overhaul/104511
[8] http://www.djj.state.ga.us/FacilitiesPrograms/fpRYDCAndYDC.shtml
[9] http://www.legis.ga.gov/Legislation/20132014/130097.pdf

Friday, February 15, 2013

Human-Sex-Trafficking at the Super Bowl

The Super Bowl is the most watched sporting event in the world.  The commercial airtime during the Super Bowl broadcast is the most expensive of the year and the most popular singers and musicians have performed during the half time show in the past. However, the Super Bowl does not only attract its fans and viewers but also traffickers. The Super Bowl is known as “the single largest human trafficking incident in the United States,” as Attorney General Greg Abbott told USA Today in 2011.[1]According to Forbes, 10,000 prostitutes were brought to Miami for the Super Bowl in 2010 and 133 underage arrests for prostitution were made in Dallas during the 2011 Super Bowl.[2]This year was no exception. A multi-agency task force arrested 85 people during the week leading up to the Super Bowl XLVII held on February 3, 2013 in New Orleans. 

Many mistakenly conceive that the human trafficking is only an international issue. However, the estimation of the number of victims provided by the United States State Department suggests that the domestic trafficking of the United States is a legitimate concern. According to the State Department, between 14,500 and 17,500 victims are trafficked into the U.S. from Asia, Central and South America, and Eastern Europe, and many more are trafficked domestically within the United States each year.[3]

Human trafficking is a form of modern-day slavery. Victims of human trafficking are subjected to force, fraud, or coercion for the purpose of commercial sex, debt bondage, or forced labor. More specifically, in the Trafficking Victims Protection Act of 2000 (TVPA), the Congress defines sex trafficking as “the recruitment, harboring, transportation, provision, or obtaining of a person for the purpose of a commercial sex act, in which the commercial sex act is induced by force, fraud, or coercion in which the person induced to perform such act has not attained 18 years of age.”[4]

 At the federal level, the Thirteenth Amendment to the U.S. Constitution which outlaws slavery and involuntary servitude protects the victims of human trafficking. In United States v. Kozminski, the 1988 United States Supreme Court Case, the Court considered whether involuntary servitude included psychological coercion within the definition of involuntary servitude but ultimately held that it did not.[5]However, the Trafficking Victims Protection Act enacted in 2000 expanded the definition of coercion to include psychological coercion. Later, Congress expanded the TVPA by allowing victims to pursue a civil action against traffickers, relaxing the definition of human trafficking and providing rehabilitative facilities for victims.

One legal scholar emphasizes that the state level anti-trafficking legislation can prevent trafficking more effectively than the federal statutory provisions mainly for three reasons.[6] In Our Backyard Slave Trade: the Result of Ohio’s Failure to Enact Comprehensive State-Level Human-Sex-Trafficking Legislation, Rocha argues that lengthy and exhaustive federal investigations often fail to prosecute traffickers. She further states that because criminal law is a state police power, individual states must design their own anti-trafficking legislation to address the needs of victims within their borders. Lastly, she argues that states can enforce anti-trafficking laws effectively by training local law enforcement officers who are much more likely to encounter victims than federal officers.

According to the studies done by Polaris Project, compared to 2007 when only twenty-eight states had anti-trafficking criminal statutes, as of July 31, 2012, forty-eight states, including the District of Columbia, have enacted anti-trafficking criminal statutes with sex trafficking offenses.[7] This improvement suggests that many states are responding to the growing concern of the domestic human trafficking. However, some states such as Wyoming, have yet to pass any human trafficking law. Because the number of human trafficking victims is only growing every year, proper measures must be taken to eliminate it. I believe that trafficking cannot be eliminated only by criminal enforcements. In addition to effective criminal enforcements, federal and state governments must offer social services and develop public awareness programs.

Minji Ku
Blogger, Criminal Law Brief

[1] https://www.oag.state.tx.us/oagnews/release.php?print=1&id=3202
[2] http://www.huffingtonpost.com/2013/02/03/super-bowl-sex-trafficking_n_2607871.html
[3] https://www.oag.state.tx.us/oagnews/release.php?print=1&id=3202
[4] http://www.acf.hhs.gov/programs/orr/resource/fact-sheet-human-trafficking
[5] http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=case&court=us&vol=487&invol=931
[6] Priscila A. Rocha, Our Backyard Slave Trade: the Result of Ohio’s Failure to Enact Comprehensive State-Level Human-Sex-Trafficking Legislation.
[7] http://www.polarisproject.org/what-we-do/policy-advocacy/current-laws

Tuesday, February 12, 2013

The Eye in the Sky: Domestic Aerial Drone Surveillance and the Fourth Amendment

The watchful eye of the American public has recently placed the Obama administration’s drone program in its sights.  The release of the Justice Department’s plan for targeted drone strikes on American citizens allegedly working for al-Qaeda has garnered considerable attention.  The staggering development of drone technology has dramatically increased the administration’s capabilities to execute strikes on specific targets abroad.  However, while the focus of most Americans is on drone surveillance and deadly strikes in distant countries, U.S. law enforcement agencies have been quietly expanding the use of drones for domestic surveillance. 

In February 2012, Congress passed the $63 billion FAA Reauthorization Act, part of which is designed to allow for the increased use of government and private drones in airspace previously reserved for passenger planes.  The FAA estimates that around 30,000 drones will be flying in U.S. airspace by 2020.

While most large metropolitan police agencies have helicopters and stationary cameras that are used for surveillance, drone capabilities far exceed those of the average traffic camera or police helicopter.  First, many drones are cheaper than helicopters, which will allow more police forces access to surveillance technology.  Second, some drones have powerful high-resolution cameras that can track people from extremely high altitudes, are capable of surveillance recording for long periods of time, and can record property details that are not visible to the human eye.

Generally, police are required to have a certain level of suspicion or probable cause before obtaining a search warrant.  But fear now stems on police abusing the extraordinary drone surveillance technology and overrunning Fourth Amendment protections against unreasonable search and seizures.  It often seems as though the legislature and judiciary are the tortoise in the race against the technological hare.  New technology often develops at a rate that exceeds the justice system’s capabilities to keep up.  But despite their tortoise-like reputation, many state legislatures are getting ahead by taking action against possible infringements by government agencies on citizens’ Fourth Amendment rights.  In its pre-session committee organizing meetings, the Florida legislature has been working hard to push a bill placing restrictions on the extent to which drones can be used for domestic surveillance in the state.  The urgency of the Florida legislature can likely be attributed to the Miami-Dade Police Department being the first domestic police agency to finalize a deal with the FAA for permission to fly drones for surveillance purposes.  But other states are catching on as well; legislators in Maine, Nebraska, Oklahoma, Oregon, Texas, Missouri, and Virginia have already introduced bills designed to place restrictions on drone usage. 

Moreover, if history is any indication of the future, it is unlikely that the Supreme Court will let the federal government trample on citizens’ Fourth Amendment protections.  John Villasenor, a UCLA Professor and Brookings Institute Fellow, looks to three Supreme Court cases from the 1980s to illustrate that the government’s use of drones for surveillance will not be without limits. 

In 1989, the Supreme Court in Florida v. Riley found that a police officer’s observation of marijuana plants in the defendant’s partially covered backyard green house did not constitute a search for which the officers needed a warrant under the Fourth Amendment.  The Rileydecision came on the heels of another Supreme Court decision, three years earlier, in which the Court made a similar finding.  In California v. Cirolo, the Supreme Court held that observation of marijuana plants by a police officer in a private airplane, without a warrant, at an altitude of 1,000 feet, did not violate the defendant’s Fourth Amendment rights.  However, the Supreme Court maintained that Fourth Amendment violations occur when police officers violate a person’s “reasonable expectation of privacy.”  Finally, in Dow Chemical v. United States, the Environmental Protection Agency (EPA), upon being denied access to a Dow Chemical plant complex, took to the air by hiring a commercial areal photographer to generate an aerial map of the complex.  The Supreme Court held the photographs did not violate the Fourth Amendment since the images were of an industrial complex taken in publicly navigable air space.

While all three of these rulings favor the government, the Supreme Court did not grant the government a free pass to disregard the Fourth Amendment when it comes to aerial surveillance.  In Dow Chemical, the court noted that the expectation of privacy that accompanies a commercial industrial complex is not the same as the expectation of privacy in an individual’s home.  The Court went on to scrutinize the level of detail in the images of the Dow Chemical complex and emphasized that the pictures did not reveal enough intimate details to raise Fourth Amendment concerns.  The Court also distinguished between a unique high-resolution camera not available to the public and a conventional camera like the one used by the EPA, a distinction the Court will likely consider in a future case on drone surveillance.  Furthermore, as Professor Villasenor notes, the use of drone surveillance at high altitudes can easily be distinguished from Ciroloand Riley where warrantless police observations were made at relatively low altitudes with the naked eye.

But a January 2012 Supreme Court case, United States v. Jones, may be more indicative of how the current Supreme Court would treat a drone surveillance case.  In Jones, the Court was presented with the issue of whether the attachment of a GPS tracking device to an individual’s vehicle, without a proper warrant, then using the device track the movements of the vehicle for one month, constitutes an unreasonable search or seizure under the Fourth Amendment.  The Court held that the respondent’s Fourth Amendment rights were violated.

However, the Court skirted many thorny issues regarding electronic surveillance by considering governmental trespass while placing the GPS device.  Nevertheless, in his concurring opinion, Justice Alito addressed the difference between short and long term electronic surveillance.  He concluded that in an age where technology is constantly changing citizens expectations about privacy, short-term surveillance might not infringe on our reasonable expectation of privacy, where secret monitoring for a long period of time­­­­––in this case four weeks––does infringe on our Fourth Amendment rights.  He wnt on to note that “where uncertainty exists with respect to whether a certain period of GPS surveillance is long enough to constitute a Fourth Amendment search, the police may always seek a warrant.”  Justice Alito’s reasoning may be a sign of the Court’s reluctance to accept long-term drone surveillance, and is certainly an indication that the Supreme Court recognizes the tension between the Fourth Amendment and new surveillance technology like drones.

The Supreme Court has no easy task.  With technology constantly evolving, it is hard to gauge what society’s “reasonable expectation of privacy” actually is.  Additionally, state legislatures need to be careful not to restrict the use of drones so much that police can not take advantage of the drones’ capacities to aid in search and rescue operations, diagramming crime scenes, or hostage situations.  However, with an informed electorate, the Supreme Court on notice, and state legislatures already taking action, it is unlikely that the United States will become the police state that some people fear.

Jared Engelking
Blogger, Criminal Law Brief