AP Exam Supreme Court Cases

Question 1

Marbury v. Madison (1803)

Answer 1

• A midnight appointment by John Adams was not delivered to William Marbury. He petitioned the court to force its delivery.
• John Marshall ruled that the provision of the Judiciary Act of 1789 that allowed Marbury’s petition was unconstitutional because it extended the Supreme Court’s original jurisdiction under Article III.
• This established judicial review - the ability of the court to determine the constitutionality of laws. It made the court equal to the other branches in power.

Question 2

McCulloch v. Maryland (1819)

Answer 2

• Maryland attempted to impose a tax on the U.S. Bank, which it thought was unconstitutional (the power of Congress to charter a bank was never specifically mentioned).
• The Court ruled that the Necessary and Proper Clause allowed Congress to charter the bank, and that Maryland could not tax it.
• This solidified the idea of the implied powers of Congress and showed that federal action overrides state action.

Question 3

Gibbons v. Ogden (1824)

Answer 3

• New York gave Aaron Ogden exclusive license to operate steamboats on the Hudson between NY and New Jersey. Thomas Gibbons also ran boats, and Ogden asked for an injunction.
• John Marshall and his court used the Commerce Clause to show that Congress had the power to regulate this sort of interstate operation.
• This broad interpretation of the Commerce Clause essentially gives Congress power over any “intercourse” activity that does not occur exclusively within state lines. Enormous power came with this.

Question 4

Plessy v. Ferguson (1896)

Answer 4

• Homer Plessy sat in a “white” car on a railroad and was arrested for breaking Louisiana’s Separate Car Act.
• The act was held to be constitutional under the provision that “separate” facilities for blacks and whites were allowed as long as they were “equal.”
• This “separate but equal” doctrine expanded into all areas of American life and lasted until 1954.

Question 5

Weeks v. United States (1914)

Answer 5

• Fremont Weeks was arrested and had items taken from his home and office without search warrants and turned over to the U.S. marshal.
• The decision stated that the illegal evidence could not be used against Weeks.
• This established the exclusionary rule for illegal evidence in federal courts.

Question 6

Schenck v. U.S. (1919)

Answer 6

• Charles Schenck, Secretary of the Socialist Party at the time, was convicted of violating the Espionage Act during WWI.
• The court ruled against Schenck, stating that he did not have a right to speak against the draft.
• This established a “clear and present danger” test for determining the constitutionality of speech.

Question 7

Gitlow v. New York (1925)

Answer 7

• Gitlow was punished under a state law for distributing socialist material that seemed to advocate a violent revolution.
• Though the court upheld Gitlow’s conviction, they ruled that the due process clause of the 14th Amendment made the First Amendment apply to states as well as the federal government.
• In addition to the incorporation of the First Amendment, this case established a “bad (or dangerous) tendency” test for speech constitutionality that replaced Schenck’s “clear and present danger” test.

Question 8

Brown v. Board of Education (1954)

Answer 8

• Oliver Brown and others in a class action suit sued the Topeka (KS) School District over their racial segregation policy.
• The court ruled in favor of Brown and the other plaintiffs, stating that “separate educational facilities are inherently unequal.”
• This overturned the 1896 Plessy v. Ferguson decision that established a “separate but equal” precedent for segregation under the law. It was a major victory of the Civil Rights Movement.

Question 9

Mapp v. Ohio (1962)

Answer 9

• Police officers, suspecting Dollree Mapp of being involved in illegal gambling and bombing, attempted to enter her home. She forced them to receive a search warrant, and when they came back they found child pornographic material unrelated to the warrant. They used this as evidence to arrest her.
• Because Mapp had been convicted on the basis of illegal evidence, the Court supported her side, declaring that the Fourth Amendment protected her.
• This action incorporated the Fourth Amendment, forcing state courts to reject illegal evidence, just as federal courts had already been required to do.

Question 10

Gideon v. Wainwright (1962)

Answer 10

• Clarence Earl Gideon was arrested in Florida for breaking and entering on the basis of little evidence. The court refused to appoint an attorney for Gideon because his case was not a capital case. He defended himself in court and was found guilty.
• The Supreme Court, after Gideon’s appeal, ruled that he did, in fact, have the right to an attorney under the Sixth Amendment.
• This decision allowed for greater incorporation of the Sixth Amendment, reaffirming a defendant’s right to counsel.

(Additional note: Gideon was given another trial and allowed counsel. He was found not guilty.)

Question 11

Griswold v. Connecticut (1965)

Answer 11

• Griswold, the Executive Director of the Planned Parenthood League of Connecticut, worked with others to operate a birth control clinic in violation of a Connecticut law that prohibited contraceptive use and counselling related to such use.
• The Court ruled that, as a result of a combination of various Amendments, individuals have a constitutional right to privacy in marital relationships, thus voiding the Connecticut statue.
• This ruling established the idea of a constitutional “right to privacy,” an idea that has been cited in numerous other cases, including the Roe v. Wade decision.

Question 12

Miranda v. Arizona (1966)

Answer 12

• Ernesto Miranda, arrested for kidnapping and rape on circumstantial evidence, signed a statement admitting guilt. He had not been informed at any point of his right to an attorney and his right to protection against self-incrimination.
• The Warren Court ruled that, unless a defendant had been made aware of and specifically waived their rights under the Fifth and Sixth Amendments, their confessions could not be used against them.
• This established the practice of “Mirandizing” suspects. The ruling included specific rules of what needed to be included in a warning, and these components remain part of the warnings given to suspects when arrested.

Question 13

Katz v. United States (1967)

Answer 13

• Charles Katz used a public phone booth to transmit illegal gambling information. The FBI recorded his calls using an eavesdropping device outside of the booth and used the information to arrest him.
• The Court ruled that, even though the device was outside the phone booth (and thus no physical intrusion occurred), the evidence still could not be used against Katz under the Fourth Amendment.
• The case extended the reach of the Fourth Amendment to all cases in which one has a “reasonable expectation of privacy,” including those in which no physical search and seizure occurs.

Question 14

Lemon v. Kurtzman (1971)

Answer 14

• Laws in Pennsylvania and Rhode Island allowed states to reimburse schools, including religious schools, in various ways (especially salary benefits). Because some of the institutions were connected with religion (many were Catholic), the laws were challenged.
• The Court ruled that, under the Establishment Clause of the First Amendment, both laws were unconstitutional.
• This ruling created a 3-part test for laws concerning religion, stating that laws must have clear secular purposes, neither advance nor inhibit religion as a primary effect, and not result in “excessive government entanglement” with religion.

Question 15

Furman v. Georgia (1972)

Answer 15

• William Henry Furman was burglarizing a home when he was discovered by the resident. He tripped while trying to escape and killed the resident, receiving the death penalty as a result.
• The Court held that, in this and similar cases, cruel and unusual punishment was imposed. Some concurrences recognized arbitrary bias in issuing capital punishment, some of which indicated racism against black defendants.
• The case caused states to re-examine capital offense statues to ensure that death penalties were not being administered in discriminatory or arbitrary ways.

Question 16

Roe v. Wade (1973)

Answer 16

• Jane Roe was a Texan who wished to have an abortion, but state law prohibited her from doing so.
• The Court ruled in her favor, stating that she had a right to an abortion because of a right to privacy first recognized in Griswold v. Connecticut. However, limits were placed on abortions based on whether the fetus could survive outside the womb.
• This case provided the consitutional basis for legal abortion in the United States, but has also led to much debate between the “pro-life” and “pro-choice” groups it createde.

Question 17

Miller v. California (1973)

Answer 17

• Marvin Miller used a mail campaign to advertise adult material that he had for sale. He was convicted under a California statue prohibiting such behavior.
• The Court did not rule that obscene material had First Amendment protection, but it did rule in Miller’s favor. However, they placed limits on regulation of such material.
• The case established a 3-part “Miller test” for obscene material, based on how an “average person” would judge such material. It also accounts for the content and value (scientific, artistic, etc.) of the work.

Question 18

United States v. Nixon (1974)

Answer 18

• Richard Nixon refused to comply with a subpoena forcing him to release tapes related to the Watergate scandal, claiming “executive privilege.”
• The court ruled 8-0 against him, stating that he did not have an unlimited executive privilege allowing such information to be withheld.
• This case created an important precedent of limits on presidential power.

Question 19

Regents of U. of California v. Bakke (1978)

Answer 19

• Allan Bakke, a white male, was denied admission to the UC Davis Medical School, which reserved special places in each class for minority students. He argued that this violated the 14th Amendment and the Civil Rights Act, and that he was excluded because of his race.
• Overall, the court ruled in Bakke’s favor and forced his admission, but Justice Powell concurred with parts of both opinions.
• California has since banned the use of race as an admissions factor. Overall, the decision prohibits racial quotas, but allows race to be used as a “factor” in the admissions process.

Question 20

Texas v. Johnson (1989)

Answer 20

• Gregory Johnson burned an American flag in front of Dallas City Hall and was convicted under Texas law.
• The Court ruled that Johnson’s flag burning was a protected form of expression under the First Amendment.
• The ruling invalidated laws in 48 states. The issue has remained contentious, and it appears that many Americans still support a ban on flag burning. Nonetheless, currently still appears to be protected.

Question 21

Tinker v. Des Moines Independent School District (1969)

Answer 21

• John Tinker and others decided to protest the Vietnam War by wearing black armbands to school. They were suspended because the school feared that it would be a disturbance.
• The Court ruled in Tinker’s favor, stating that the armbands would not have been a major distraction in school and that Tinker’s action was protected under the First Amendment.
• This established the Tinker test, which is based on disruption to school decorum or the educational process. However, courts have subsequently limited Tinker’s application in certain cases.

Question 22

Hazelwood v. Kuhlmeier (1988)

Answer 22

• A school-sponsored newspaper at Hazelwood East High School was ordered to withhold two pages that were said to contain inappropriate articles.
• The Court ruled in the school’s favor, stating that the school had the right to censor a publication that it sponsored and not promote certain speech in it.
• The case set a precedent that student speech may sometimes be limited in school newspapers.

Question 23

New York Times v. United States (1971)

Answer 23

• The New York Times and the Washington Post were blocked by the Nixon administration from publishing the “Pentagon papers” during the Vietnam war as a national security measure.
• The Court ruled in favor of the papers, stating that their right to publish the documents was protected under the First Amendment.
• The ruling required the government to show “grave and irreparable danger” if they were to prohibit the publishing of certain documents.

Question 24

Zelman v. Simmons-Harris (2002)

Answer 24

• A school voucher program in Cleveland allowed private schools to participate, including religious schools. Some argued that this violated the Establishment Clause.
• The Court ruled that the Establishment Clause was not violated and that individuals, not the government, endorsed the institutions that received the aid.
• This established a 5-part Private Choice Test, designed to ensure religious neutrality in such programs while not disallowing religious institutions entirely.

Question 25

Agostini v. Felton (1997)

Answer 25

• The case involved the prohibition of public school teachers from instructing in parochial schools.
• The Court, in this case, overturned a previous decision that prohibited such teaching under the Establishment Clause. They now found that public school teachers did not violate the Constitution by teaching in parochial schools.
• The court established a precedent that the Establishment Clause would only be violated by policies that generated excessive conflict between church and state.

Question 26

Grutter v. Bollinger (2003)

Answer 26

• Barbara Grutter, a white applicant to the University of Michigan Law School, was denied admission.
• The Court ruled that, since the school considered race along with a number of other factors in order to obtain educational benefits through diversity, there was no issue with the process and it did not unduly hurt white applicants.
• The case essentially upheld the practice of affirmative action.

Question 27

Webster v. Reproductive Services (1989)

Answer 27

• The case dealt with the constitutionality of a Missouri law that restricted the use of public funds and facilities in abortions and placed other restrictions on mothers and physicians.
• The Court upheld the law as constitutional.
• Though this case did not change the essential provisions of Roe v. Wade, it did narrow them.

Question 28

Planned Parenthood v. Casey (1992)

Answer 28

• The case dealt with the constitutionality of Pennsylvania regulations that required informed consent, husband notification, and other practices before an abortion could be performed.
• The Court upheld most of the provisions (except the husband notification requirement) as constitutional under their framework, while still reaffirming Roe v. Wade.
• The case established a new framework to test abortion regulations: an “undue burden” framework that looked for “substantial obstacles” that prohibited abortions before viability.

Question 29

Brandenburg v. Ohio (1969)

Answer 29

• Clarence Brandenburg was a KKK leader who was convicted under an Ohio law that prohibited public speech advocating illegal activities.
• The Court ruled that such generic hate speech was constitutional, as it was not actually likely to incite imminent lawless action.
• The Brandenburg test, involving the likelihood of speech inciting imminent lawless action, is still used to determine the constitutionality of hate speech.

Question 30

West Virginia Board of Education v. Barnette (1943)

Answer 30

• The case dealt with a requirement that students honor the American flag in schools - an issue for Jehovah’s Witnesses.
• The Court ruled that the requirement was unconstitutional under the First Amendment.
• The decision in Barnette led the way for greater tolerance of religiously-motivated actions and more religious exemptions by the Supreme Court.

Question 31

Scott v. Sandford (1857)

Answer 31

• Dred Scott, a slave who lived in the free state of Illinois (freedom guaranteed by the Missouri Compromise), sued to gain his freedom.
• The Court ruled that Scott, as a descendant of slaves, was not a citizen of the United States. Furthermore, the Court declared that the Missouri Compromise was unconstitutional.
• The Dred Scott decision is one of the most infamous in American history, and it incited anger among opponents of slavery.

Question 32

Harper v. Virginia State BOE (1966)

Answer 32

• Annie Harper filed suit, stating that the Virginia poll tax was unconstitutional.
• The Court agreed with Harper, finding that the Equal Protection Clause had been violated.
• This case incorporated the 24th Amendment, extending poll tax restrictions to state elections.

Question 33

Smith v. Allwright (1944)

Answer 33

• Lonnie Smith, an African-American, was denied the right to vote in a Texas Democratic Primary. He argued that this was unconstitutional.
• The Court found that, even though the Democratic Party was a “voluntary” organization, the fact that elections were involved prohibited the party from carrying out such discrimination.
• This ended all-white primary elections held by the Democratic Party and helped to give greater rights to blacks.

Question 34

Hill v. Stone (1975)

Answer 34

• The case dealt with Fort Worth, TX bond elections that were limited to those who owned taxable property.
• The Court ruled, “any classification restricting the franchise on grounds other than residence, age, and citizenship cannot stand unless the district or State can demonstrate that the classification serves a compelling state interest.”
• More fighting against voting restrictions?

Question 35

Gomillion v. Lightfoot (1960)

Answer 35

• The case involved a gerrymandered election district in Alabama that was believed to exclude blacks and violate the Fifteenth Amendment.
• The Court found that the 15th Amendment was, in fact, violated by the boundary.
• The case set a precedent prohibiting racial discrimination in the drawing of election districts.

Question 36

Lawrence v. Texas (2003)

Answer 36

• John Lawrence was found in his apartment engaging in a consensual homosexual act that was illegal under Texas law.
• The Court found in Lawrence’s favor, stating that the Due Process clause protected him. They also overturned an earlier decision finding that a similar statue was constitutional.
• Lawrence has been cited in other sex cases throughout the U.S.

Question 37

Loving v. Virginia (1967)

Answer 37

• Mildred Jeter and Richard Loving, a black woman and white male, were convicted under a Virginia statue forbidding their marriage.
• The Court found that their rights were violated under the Equal Protection Clause.
• The decision led to more interracial marriage. Also, it has appeared in discussions regarding same-sex marriage.

Question 38

New Jersey v. T.L.O. (1985)

Answer 38

• T.L.O. was a teenager smoking in a high school bathroom. A principal searched her purse and found marijuana.
• The Court found that the search did not violate the Fourth Amendment. Rather than “probable cause,” there was “reasonable suspicion” to believe that drugs were present.
• Essentially, this shows that students in schools do not receive the same Fourth Amendment protections as adults.

Question 39

Morse v. Fredrick (2007)

Answer 39

• Fredrick, a student, held a banner at a school event that said “Bong Hits 4 Jesus.” He was suspended by the principal.
• The Court ruled that the suspension was allowed, stating that the school’s interest in prohibiting drug use was more important than the student’s right to express a pro-drug message.
• Not all of the issues of the case were resolved. However, it did place greater restriction on student expression.

Question 40

Hustler Magazine v. Falwell (1988)

Answer 40

• Hustler Magazine ran a parody about Jerry Falwell, a Fundamentalist minister, involving a ficticious sexual encounter with his mother, among other things. He sued for libel and emotional distress.
• The Court found that Hustler’s portrayal was constitutional because no false statements were made intending “actual malice.”
• The ruling protects publications in cases involving speech about public figures.

Question 41

Citizens United v. FEC (2010)

Answer 41

• Citizens United fought against a law that limited large election-related spending and marketing while trying to release a movie about Hillary Clinton.
• The Court held that corporate funding of independent political broadcasts cannot be limited under the First Amendment.
• The case led to the creation of Super PACs in elections, as well as fierce debate.

Question 42

Boy Scouts v. Dale (2000)

Answer 42

• A former Eagle Scout’s membership was revoked upon discovery that the member, James Dale, was gay.
• The Court ruled that this was permissible under the Boy Scouts’ “right of association.”
• This ruling allowed the Boy Scouts to bar gay troop leaders. It also set a precedent for certain other organizations.

Question 43

Roper v. Simmons (2005)

Answer 43

• Christopher Simmons was sentenced to death as a minor, but his execution faced repeated delay. After Atkins v. Virginia was decided, his case received another look.
• The Court found that, due to evolving standards of decency, the execution of minors was cruel and unusual under the Eighth Amendment.
• Several minors facing execution were released from the punishment after this case was decided. It extended the precedent set for the mentally ill in Atkins v. Virginia.

Question 44

Engle v. Vitale (1962)

Answer 44

• The State of New York allowed a voluntary, nondenominational prayer at the start of each school day that specifically made references to God.
• The Court determined that this was not constitutional under the Establishment Clause, as it essentially showed New York’s approval of a particular religious ideology.
• The ruling became the basis for later restrictions on school prayer. It has also remained unpopular with some Americans, despite the long time since it took place.

Question 45

Roth v. United States (1957)

Answer 45

• Samuel Roth, a New York bookstore owner, mailed obscene material across state lines.
• The Court ruled that obscenity was not constitutionally protected expression. The test for obscenity involved whether the material in question would appeal to the prurient interest of the average person.
• The Roth test was later abandoned in Miller v. California, which gave communities the power to decide whether material was obscene.

Question 46

Kennedy v. Louisiana (2008)

Answer 46

• Patrick Kennedy was sentenced to death after raping a young girl.
• The Court ruled that this counted as cruel and unusual punishment, building on the precedent of previous cases like Coker v. Georgia.
• Some officials criticized the decision. Regardless, it has led to the narrower application of the death penalty.

Question 47

Vernonia School District v. Acton (1995)

Answer 47

• The Vernonia School District adopted a drug-testing policy for athletes. Acton was denied membership on a school football team after refusing to consent to tests.
• The Court ruled that this did not violate the Fourth Amendment, and that legitimate state interests were being protected.
• This ruling, along with the later ruling in Earls, gave greater liberty to schools to drug test athletes and participants in other extracurricular activities.

Question 48

Board of Education v. Earls (2002)

Answer 48

• A school policy requiring consent to drug testing for participation in any extracurricular activity was challenged.
• The Court, using a precedent set in the Acton case, ruled that this was consistent with the Fourth Amendment and reasonably supported the school’s objective of reducing drug use.
• This expanded the provisions set forth in the Acton case and allows schools to require more drug testing for students.

Question 49

Bush v. Gore (2000)

Answer 49

• The Florida Supreme Court required recounting of votes during the 2000 election. This was challenged by Bush and Cheney.
• The Court ruled that the Florida Supreme Court had unconstitutionally created election law with its ruling and that ballot counts were inconsistent. Thus, the recount was stopped.
• The decision essentially ended the 2000 presidential race and gave the presidency to George W. Bush. It has remained controversial ever since, and even former justices have questioned the Court’s wisdom in taking the case.

Question 50

Edwards v. Aguillard (1987)

Answer 50

• A Louisiana law stated that, if evolution were to be taught in schools, it must be taught alongside creationist theory.
• The Court determined, under the precedent set in Lemon v. Kurtzman, that this was unconstitutional, failing on all three prongs of the test.
• The ruling contributed to the separation of church and state in public education. Some continue to argue against this, however.

Question 51

District of Columbia v. Heller (2008)

Answer 51

• A D.C. law prohibiting handguns was challenged by a security guard who claimed a violation of his rights under the Second Amendment.
• The Court found the D.C. law unconstitutional, claiming that the Second Amendment applies to individual handgun ownership and not just militia use.
• D.C. has continued its attempts to ban firearms, but the case still sets an important precedent for gun owners.

Question 52

Clinton v. City of New York (1998)

Answer 52

• Bill Clinton made changes to laws under the Line Item Veto Act that were challenged by various groups.
• The Court found the Line Item Veto Act to be unconstitutional, declaring that it was an improper extension of presidential power.
• Since this decision, the line item veto has been banned, though some have attempted to bring such a measure back.

Question 53

Gonzales v. Carhart (2007)

Answer 53

• The Partial-Birth Abortion Ban Act was challenged by abortion doctors who stated that it would be an “undue burden” as defined in Planned Parenthood v. Casey.
• The Court found that no undue burden was imposed and that the act was, in fact, constitutional.
• Some have criticized the Court for this decision (but that usually happens with every decision…)

Question 54

U.S. v. Eichman (1990)

Answer 54

• The case dealt with a challenge to the constitutionality of the federal Flag Protection Act.
• The Court, using the precedent of Texas v. Johnson, declared the national flag burning law unconstitutional, once again supporting the right of Americans to burn flags as symbolic speech.
• As Texas v. Johnson had already set a precedent for this kind of thing, nothing actually changed that much. Some guys got together and tried to make a flag burning amendment, though.

Question 55

McDonald v. Chicago (2010)

Answer 55

• After the decision in D.C. v. Heller, Chicago gun bans were challenged using similar arguments.
• The Court, using the precedent in the Heller case, declared the bans unconstitutional.
• This ruling incorporated the Second Amendment (the last amendment to be incorporated by the Court).

Question 56

Minnesota v. Carter (1999)

Answer 56

• Several friends were bagging cocaine in a window and were seen by a police officer. They argued that this was an illegal search.
• The Court ruled that Fourth Amendment protections do not extend to short-term guests of a household.
• This reduced the power of the Fourth Amendment, I guess.

Question 57

Atkins v. Virginia (2002)

Answer 57

• Daryl Atkins was a mentally handicapped individual who was sentenced to death.
• The Court ruled that the death sentence would be cruel and unusual punishment for a mentally handicapped criminal.
• The precedent set in Atkins was used in some subsequent trials, including Roper v. Simmons.

Question 58

Heart of Atlanta Motel v. United States (1964)

Answer 58

• The Heart of Atlanta Motel prohibited blacks, running afoul of a portion of the Civil Rights Act.
• In a 9-0 decision, the Court determined that the Civil Rights Act was constitutional and that the hotel’s business could be regulated as a result of the commerce clause. In other words, they and others had to accept black guests.
• This was likely a significant development in the Civil Rights Movement.

Question 59

Stoner v. California (1964)

Answer 59

• Joseph Stoner was convicted of robbery and had items seized from his hotel room.
• The Court found that this was a violation of Stoner’s Fourth Amendment rights, even though he was at a hotel and not in his own home.
• The ruling required expansion of the use of search warrants.

Question 60

Stanley v. Georgia (1969)

Answer 60

• Robert Stanley had his home searched with a warrant. Police found reels of film containing obscene material and arrested Stanley.
• The Court ruled that, under the First and Fourteenth Amendments, Stanley had a right to personal privacy. Thus, the private possession of obscene materials could not be a crime.
• The case limited the power of the government in cases of privately owned obscenity. It did make exceptions for certain types of material, such as child pornography.

Question 61

Wolf v. Colorado (1949)

Answer 61

• Julius Wolf acted as a defendant in a case that asked whether the exclusionary rule for evidence implied by the Fourth Amendment applied to states.
• The Court ruled that the exclusionary rule did not apply, and that certain evidence could be used in state trials.
• The ruling was essentially overturned by that in Mapp v. Ohio.

Question 62

Buckley v. Valeo (1976)

Answer 62

• The case tested the constitutionality of campaign spending limits and restrictions as well as the Federal Election Commission, which oversaw them. This was challenged, using the First Amendment as a basis.
• The Court found that individual contributions could be restricted, but that expenditure limits for candidates with personal funds were unconstitutional.
• This is one of the major cases referenced when dealing with campaign finance issues.

Question 63

Terry v. Ohio (1968)

Answer 63

• John Terry and others were observed and frisked by a plainclothes police officer, who found weapons on two of three group members. Terry received 3 years in jail.
• The Court ruled that this was constitutional under the Fourth Amendment because the search was carried out to protect the officer’s safety.
• This gave officers greater liberty to search people, areas in cars, and other places for their own personal safety and protection.