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Assault and Battery: Handcuffs

     A corporal smashed a car's windshield while lunging at it when it failed to turn at a roadblock as directed. The car rolled the corporal, who then forcibly handcuffed and arrested the motorist. In an excessive force lawsuit brought by the motorist, the corporal was entitled to qualified immunity. The court found that the forcible handcuffing was justified by the motorist's actions, which interfered with an officer's performance of his duty. The court also stated that even if the corporal violated the motorist's rights by breaking his windshield, any right involved was not clearly established. Claims against the county were rejected because the county did not set policy for the sheriff's department, as well as claims against the sheriff's department, based on the facts. Vandewalle v. Moffa, #3:07-CV-400, 2009 U.S. Dist. Lexis 19303 (N.D. Ind.).

Assault and Battery: Physical

     An arrestee failed to show that officers used excessive force against him while arresting him at the scene of a domestic disturbance. He attempted to evade arrest and they were forced to drag him from underneath a bush, administer baton strikes to his upper left thigh to try to make him show his hands, and finally sprayed mace in his face, after which he finally presented his hands for handcuffing. Even then, he refused to cooperate by walking to a police vehicle. Additionally, officers had, early in the incident, observed a silver object in his hands, which they thought might be a gun, although it later turned out to be either a screwdriver or a pair of handcuffs. The court found nothing in the record to support the arrestee's own "contradictory" testimony that he cooperated with the officers, did not resist, and that the officers gratuitously used excessive force against him. Based on the officer's testimony and report and a medical assessment from an emergency room doctor, the court found, no reasonable jury could believe the arrestee's version of the incident. Reed v. City of St. Charles, No. 07-2713, 561 F.3d 788 (8th Cir. 2009).

Assault & Battery: Stun Guns/Tasers

     Officers acted reasonably in pursuing a motorist to his home after he drove away instead of stopping as they commanded because he was violating a noise ordinance. They followed him inside his house and used a Taser on him while trying to subdue him. His wife picked up a bar stool and grabbed a knife in an effort to prevent the officers from tasing her husband again, threw one officer's Taser outside the house, and then locked that officer out of the house. The officers' actions were justified by their hot pursuit of the husband, and the wife's hostile actions. They had exigent circumstances to enter the home, probable cause to prosecute the wife for menacing them, and did not use excessive force under the circumstances. Bash v. Patrick, #2:08-cv-240, 2009 U.S. Dist. Lexis 30163 (M.D. Ala.).

Attorneys' Fees: For Plaintiff

     After a $20,000 settlement was reached in an arrestee's lawsuit concerning the use of a Taser against him during an arrest, the trial court awarded him $200,000 in attorneys' fees and $15.034.10 in costs. The appeals court found that the trial court failed to explain how it arrived at the number of hours of attorneys' fees awarded or how it arrived at the applicable hourly rate to be paid, making "meaningful review" on appeal "impossible." The plaintiff only prevailed on the excessive force claim, with summary judgment entered against the plaintiff on other claims, including wrongful arrest/detention, and municipal liability. While the appeals court found that all claims in the case were related, it also found that attorneys' fees must be "adjusted downward" when a plaintiff "has obtained limited success" on his claims, and the "result does not confer a meaningful public benefit." The plaintiff, the court noted, received in the settlement roughly one-fourth of the damages in excess of $75,000 sought in his complaint and less than one-tenth of the $251,000 he requested in settlement. The appeals court, therefore, ordered the trial court to reconsider the amount of attorneys' fees and costs to be awarded. McCown v. City of Fontana, No. 07-55896, 550 F.3d 918(9th Cir. 2008).

     After a jury awarded only nominal damages of $1 in a lawsuit claiming violation of a 9-year-old child's rights when she was arrested and handcuffed for threatening a teacher at school, allegedly without probable cause, the trial court awarded $70,532.93 in attorneys' fees. A federal appeals court vacated the award of attorneys' fees, noting that exceptional circumstances must be shown to justify the award of attorneys' fees. It ordered further proceedings by the trial court on whether such circumstances existed, finding no support currently for the award, and ordered that the trial court provide detailed findings if it determined that an attorneys' fee award was required. Gray v. Bostic, #08-15152, 2009 U.S. App. Lexis 7876 (11th Cir.).

Domestic Violence

     Officers did not act unreasonably for arresting a man for violating a domestic violence order of protection after his wife told them he had violated the order. A reasonable officer would not have believed her later statement that the protection order had been vacated when she complained about her husband violating it after the date of the alleged vacating. Further, the record contained no evidence of a written order vacating the protective order. Even if it actually had been vacated, under these circumstances no reasonable officer would have believed that the arrest was illegal, given no proof that the order was not still in effect. Martin v. Russell, #08-2577, 2009 U.S. App. Lexis 9642 (8th Cir.).

False Arrest/Imprisonment: No Warrant

     Even if a trial court erred in instructing a jury that officers could have lawfully arrested the plaintiff for actions he took in his front yard, this was a harmless error, since the arrest of the plaintiff was not based on his actions in his front yard, but for allegedly assaulting the officers in his backyard. Claims of unlawful arrest, excessive force, and malicious prosecution were rejected. The trial court properly rejected claims against a mayor and a mayor's assistant, since there was no evidence that they participated in any violation of the arrestee's rights. The plaintiff was properly awarded $20 in damages on his claim that officers engaged in unreasonable search and seizure when they came to his house, accompanied by a police dog, to ticket abandoned vehicles, and properly denied the plaintiff attorneys' fees in light of his limited success on only one of several claims, and the award of nominal damages. Brocuglio v. Proulx, #07-1676, 2009 U.S. App. Lexis 8892 (Unpub. 2nd Cir.)

     Despite the fact that an arrestee was ultimately not convicted of burglary charges, the arresting officers still had probable cause at the time of the arrest under the totality of the circumstances. He had been identified by the person who reported the burglary, and refused to respond to the officers' questions when found standing in a parking lot near the vicinity of the burglarized car. Additionally, his lack of cooperation during the booking process interfered with the officers' ability to get clear fingerprints from him at the time. Young v. City of Wildwood, #08-2035, 2009 U.S. App. Lexis 8581 (Unpub. 3rd Cir.).

     Police had probable cause to arrest a motorist for driving under the influence because he was acting erratically, appeared intoxicated, and could have constituted a danger to the police, others, and himself. It turned out, in fact, that he had experienced a diabetic incident while driving his car. When the officers observed that he had an insulin pump, they called for emergency medical services, and acted to assist him when they became aware of his medical needs, five minutes after their arrival. The court found no evidence of excessive use of force, including no evidence of the excessive use of force in handcuffing. Solovy v. Morabito, #2:08-cv-12303, 2009 U.S. Dist. Lexis 25701 (E.D. Mich.).

     The U.S. Supreme Court has declined to review the rejection of a police officer's lawsuit against prosecutors and officers for arresting and prosecuting him for the murder of his wife, who actually died of natural causes, a rare heart condition, as determined by a medical exam. The federal appeals court below held that prosecutors had absolute immunity on their decision to charge him, and an officer who testified during grand jury proceedings had absolute witness immunity. Further, probable cause to arrest existed at the time of the arrest, based on an initial determination by an on-call medical examiner who stated that the cause of death was asphyxiation. While charges were later dropped, by that time the officer lost custody of two young daughters, and suffered a suspension from his job. Andros v. Gross, No. 07-2259, 2008 U.S. App. Lexis 20187 (Unpub. 3rd Cir.), cert. denied, Andros v. Gross, 08-919, 2009 U.S. Lexis 3149.

     Officers had probable cause to arrest a man for grand larceny of a yacht which a repossession company had reported stolen. The man had taken back the yacht after it was repossessed. The officers, at the time of the arrest, were presented with papers by the repossession company showing that it had repossessed the yacht and executed an affidavit as a victim of theft. It was only later that more investigation showed that the arrestee had entered into an agreement for repayment with the company holding the mortgage on the yacht, and therefore had not stolen t. Corines v. Broward County Sheriff's Dept., #08-14822, 2009 U.S. App. Lexis 7809 (Unpub. 11th Cir.).

     The plaintiff's arrest for armed robbery was supported by probable case when the victim identified him as the black male who robbed him at gunpoint before fleeing in a blue vehicle. Additionally, at the time, the plaintiff admitted to the detective that he was involved in the crime. Atterbury v. Miami Police Dept., #08-15519, 2009 U.S. App. Lexis 7690 (Unpub. 11th Cir.).

     An officer ordered a man out of a parked car with parking lights on outside a drug store when he observed him apparently sleeping, and breathing rapidly. The officer patted him down and arrested him for being under the influence of a controlled substance. A federal appeals court found that there was reasonable suspicion to order that man out of the car and investigate the possibility of use of a controlled substance, but that the pat-down search violated the plaintiff's Fourth Amendment rights in the absence of anything to provide reasonable suspicion of possession of a weapon. Impoundment of the suspect's car after his arrest was justified under the "community caretaking" doctrine. Wrongful arrest and detention claims were rejected. Ramirez v. City of Buena Park, #04-56832, 2009 U.S. App. Lexis 6394 (9th Cir.).

False Arrest/Imprisonment: Warrant

     When an officer's investigation showed that a suspect had knowledge of violent incidents involving a 15-year-old boy residing at a intermediate care facility who was having trouble adjusting there, she had probable cause to seek an arrest warrant for cruelty to the infirm. The youth suffered from a seizure disorder, violent incidents, severe retardation, and schizophrenia, but the arrestee allegedly refused to comply with recommendations of the resident's care team that he be moved elsewhere and be subject to one-on-one supervision. This allegedly resulted in harm to the resident from more violent incidents. These facts, recited in the warrant affidavit, were sufficient to provide probable cause for the arrest. Barfield v. Louisiana, #08-30334, 2009 U.S. App. Lexis 7258 (Unpub. 5th Cir.).

First Amendment

     A police officer was not entitled to summary judgment in a "pro-life" activist's lawsuit over prohibiting him from walking in an alley near an abortion clinic, thereby preventing him from being able to speak to the clinic's clients about his anti-abortion beliefs. While the officer said that his actions were based on concerns for pedestrian safety, the appeals court noted that the clinic's clients and personnel were not prevented from entering the alley to use its only entrance, despite the presumed presence of the same pedestrian safety concerns. Further proceedings were ordered on First Amendment claims. McTernan v. City of York, Pa., #07-4437, 2009 U.S. App. Lexis 8884 (3rd Cir.).

     A federal district judge granted a temporary restraining order enjoining a prosecutor from bringing criminal charges against the plaintiffs' minor children for "sexting," the practice engaged in by them of using cellphones or the Internet to send or post sexually suggestive text messages and semi-nude or nude photographs of themselves. The plaintiff parents sought the order to prevent criminal charges involving photos that they said did not show sexual activity. The plaintiffs argued that the threatened prosecution violated First Amendment rights to self-expression and the children's right to be free from compelled speech, as well as the parents' rights, under the Fourteenth Amendment, to determine the upbringing of their children. The "compelled expression" claim was based on the prosecutor's demand that the minors write essays stating that what they did was wrong, which they did not believe, or face felony charges. Miller v. Skumanick, #3:09cv540, 2009 U.S. Dist. Lexis 27275 (M.D. Pa.).

Firearms Related: Intentional Use

****Editor's Case Alert****

     A federal appeals court ruled that an officer was not liable for shooting and killing a suspect who he observed reaching into a boot, possibly to get a weapon. The shooting officer was engaged, along with his fellow SWAT team members, in executing an arrest warrant for two persons, one being the man he shot. This man had allegedly pistol whipped a second man and threatened to kill him, then going into his mobile home, purportedly to "test" his rifle. Entering the home, the officer observed his feet moving below a closed bedroom door and then saw him reaching into the boot when the door yielded slightly. "This court has upheld the use of deadly force where a suspect moved out of the officer's line of sight and could have reasonably been interpreted as reaching for a weapon." Ontiveros v. City of Rosenberg, Texas, #08-20081, 2009 U.S. App. Lexis 6909 (5th Cir.).

Freedom of Information

     A man serving two consecutive life sentences for murder of two F.B.I. agents filed Freedom of Information Act requests with the F.B.I., seeking disclosure of all documents it has concerning him. While the F.B.I. disclosed 70,419 pages of records, it withheld 10,557 pages, contending that they were exempt from disclosure under exemptions to the Act, including those concerning records that "could reasonably be expected to constitute an unwarranted invasion of personal privacy" or "could reasonably be expected to disclose the identity of a confidential source." The trial court, after examining F.B.I. affidavits and a sample of approximately 500 withheld documents, upheld most of the F.B.I.'s actions in withholding the documents. The sole exception was an order directing the F.B.I. to disclose to the plaintiff any documents about a certain individual if they had previously been revealed to other Freedom of Information Act requesters. Upholding this result, a federal appeals court rejected arguments that the trial judge was required to review all withheld documents rather than a sample, and finding that the exemptions at issue were properly applied to bar the disclosure of most of the documents the plaintiff still sought. Peltier v. FBI, No. 07-1745, 2009 U.S. App. Lexis 9023 (8th Cir.).

Governmental Liability: Policy/Custom

     A man arrested and prosecuted for murder claimed that officers fabricated the case against him by pressuring witnesses to falsely identify him and ignoring evidence that was inconsistent with his participation in the crime. He further claimed that a prosecutor did not provide him with available exculpatory evidence. The federal appeals court found that the plaintiff had adequately pled a case for the city being liable for false arrest and malicious prosecution by virtue of failure to train officers and prosecutors in proper identification and investigation techniques and procedures or the need to reveal exculpatory evidence to criminal defendants. Claims based on failure to adequately supervise and discipline officers and prosecutors also survived. The verdict acquitting the plaintiff in the criminal prosecution, however, defeated any civil rights claim based on the failure to provide exculpatory evidence. Ambrose v. City of New York, #02-CV-10200, 2009 U.S. Dist. Lexis 27498 (S.D.N.Y.).

Homeless Persons

     A homeless arrestee claimed that he was picked up by an officer for loitering, and then taken to a wooden area where the officer beat and stabbed him. A federal appeals court ruled that a claim by the arrestee that the county was liable for his injuries because it has an unwritten policy that homeless people should be relocated to other counties should have survived summary judgment because evidence was presented of five officers who allegedly knew of the policy. Additionally, there was expert testimony that such a policy made violations of the rights of homeless persons foreseeable. A claim against the county for negligent hiring of the officer was rejected because the only violent act in the officer's record was the shooting of a home invader. The appeals court also rejected a claim against the county for inadequate training or supervision. There was evidence that revealed that the county investigated reports concerning the officer's handling of arrests, provided the officer with counseling and retraining, and subjected him to discipline, which did not show "deliberate indifference" to a known problem. Williams v. DeKalb County, #07-14367, 2009 U.S. App. Lexis 9839 (Unpub. 11th Cir.).

Injunctive Relief

     Online want ads firm www.craigslist.com agrees to drop an erotic services category. In doing so, however, it substituted an "adult services" category, which continues to include ads for unlicensed massage services and escorts, leading some to question how substantive the change made was, while the company contended that the ads in the new category were now screened for potentially illegal content. The substitution of the "adult services" category for the "erotic services" category was effective for the company's classified ad pages for U.S. cities, while the "erotic services" category was evidently retained for pages for some foreign cities. The Cook County, Illinois Sheriff had sued the firm, claiming that his office had incurred high costs while enforcing state solicitation laws, and seeking an injunction. Dart v. Craigslist, Inc., #09-cv-1385 (N.D. Ill.). Click here to view the Complaint in the case. Also, on May 22, 2009, a federal judge entered an agreed order restraining the South Carolina Attorney General from prosecuting craigslist.com or its officers regarding site content, specifically ads that allegedly led to prostitution arrests, while the company pursues a lawsuit against the state over threats of such prosecution. The complaint in the case can be found at the following link. Craiglist, Inc. v. McMaster, #2:09-cv-01308, (U.S. Dist. Ct. S.C.).

Malicious Prosecution

     A man arrested and prosecuted following a bar fight could not pursue malicious prosecution claims when he was acquitted of aggravated assault and public intoxication, but found guilty of disorderly conduct. The court ruled that, because of the conviction on one charge, the plaintiff could not show that the prosecution terminated in a manner favorable to him. All three charges, the court noted, were aimed at punishing the same underlying misconduct. Kossler v. Crisanti, #06-3241, 2009 U.S. App. Lexis 8432 (3rd Cir.).

Negligence: Vehicle Related

     A passenger in a vehicle claimed that he was injured when a parole officer turned in front of the vehicle in which he was riding and collided with it. The officer allegedly failed to use a turn signal, horn or warning lights or siren before turning. At the time, the officer was pursuing a parole absconder and trying to cross southbound lanes and turn into a parking lot to reverse direction and pursue a vehicle meeting the description of the suspect's vehicle. Because the officer's car was a police vehicle involved in an emergency operation under New York state law, the court found that his failure to signal or sound his horn before turning was not reckless disregard or conscious indifference, the type of conduct required to impose liability on the driver of an emergency vehicle. Summary judgment was granted to the defendant state. Rusho v. New York, #112572, 2009 N.Y. Misc. Lexis 1018 (Ct. of Claims).

Pursuits: Law Enforcement

****Editor's Case Alert****

     A police officer was entitled to qualified immunity for allegedly terminating the threat posed by an intoxicated driver he was chasing at high speed down a rural narrow curvy highway by bumping his vehicle from behind, sending it off the road into a ravine. The motorist subsequently died from resulting injuries. The fact that the officer may have violated department policy or a radioed order from a supervisor to terminate the chase did not alter the determination that his actions did not violate clearly established law for purposes of qualified immunity or that his actions were reasonable under the circumstances. "Stuck between the choice of letting a presumptively intoxicated and reckless driver continue unabated or bumping the suspect off the road," the court stated, the officer "chose the course of action that would potentially save the lives of individuals who had no part in creating the danger." The court also pointed to the U.S. Supreme Court's ruling in Scott v. Harris, #05-1631, 550 U.S. 372 (2007), that "a police officer's attempt to terminate a dangerous high-speed car chase that threatens the lives of innocent bystanders does not violate the Fourth Amendment, even when it places the fleeing motorist at risk of serious injury or death." Scott, however, was not determinative in the immediate court's ruling, as it was decided after the chase at issue, which occurred in 2000. The fact that the officer only raised the qualified immunity defense fifty-two months after the lawsuit was filed, the appeals court held, did not prejudice the plaintiff when it was still two months before the close of discovery and six months before a pre-trial conference. Pasco v. Knoblauch, No. 08-60242, 2009 U.S. App. Lexis 9448 (5th Cir.).

Search and Seizure: Home/Business

     A nightclub stated viable claims for violation of Fourth Amendment rights in alleging that officers entered the premises without a warrant, without probable cause, and for the purpose of investigating possible drug use there, frisking patrons, handcuffing a number of them without making arrests, ordering lights turned on at the club, and generally acting in an "intimidating" way. Claims related to an earlier incident at the club were time barred as the lawsuit was filed four days after the applicable two-year statute of limitations expired. The Illusions of the South, Inc. v. City of Valdosta, #7:07-cv-6, 2009 U.S. Dist. Lexis 27154 (M.D. Ga.).

     A homeowner changed the locks on her house when her 18-year-old son stayed overnight at his girlfriend's residence, and told her son, when he returned home, that he no longer lived there. An officer made a warrantless entry into the home with the son, over his mother's objections, to help retrieve the son's belongings. The mother told the officer that her son no longer lived there and could not consent to the officer's entry, and had not even been able to give such consent when he did live there. The officer determined that the son could consent, and proceeded to make the entry. A federal appeals court overturned the trial court's judgment that no constitutional violation had occurred with the entry. It found that a reasonably jury could find, under these circumstances, that the son intended to live elsewhere, had moved out, and could not consent to the officer's entry. Further proceedings were ordered on the mother's Fourth Amendment claims. Kirley v. Williams, #07-2728, 2009 U.S. App. Lexis 9696 (Unpub. 3rd Cir.).

     SWAT officers who staged a raid on a bar without a warrant were not entitled to qualified immunity in the bar owner's lawsuit claiming that the raid was illegal, involved unreasonable violence, and was not justified by specified state laws allowing "administrative inspection" of licensed bars. Club Retro LLC v. Hilton, #08-30512, 2009 U.S. App. Lexis 9864 (5th Cir.).

Search and Seizure: Warrant

     A federal trial court found that a homeowner and her son made a "substantial" showing that an officer lied in his affidavit seeking a search warrant for their home by saying that he found mail addressed to the residence in garbage bags. The son swore that he and his mother shredded any documents that showed their address. However, the affidavit for the search warrant, even lacking the statements about the mail, still showed probable case, based on the officer's statement concerning an anonymous tip of drug activity in the home, and his subsequent investigation, which observed heavy foot traffic there and found marijuana residue in the garbage bags. The officer, therefore, was given qualified immunity on claims related to the validity of the warrant. Further proceedings were ordered, however, on whether officers executing the search warrant failed to knock and announce their presence before entering. Cotton v. Sassak, #2:06-cv-15208, 2009 U.S. Dist. Lexis 25480 (E.D. Mich.).

     An officer acted in an objectively reasonable manner in seeking to obtain a search warrant for a home following a shooting. He heard the shooting victims identify two assailants and gathered evidence identifying them and linking them to a residence and to the victim's roommate. Additionally, both the victim and his roommate identified one of the residents of the home from a photo array as a participant in the crime. General allegations that the officer, in his warrant application, engaged in the deliberate hiding of material and exculpatory information did not suffice to show that the warrant was lacking in probable cause. There was no indication that the officer had any personal stake in the case or that he acted in any way other than as an impartial investigator. There was also no evidence that the warrant affidavit included deliberate falsehoods, or that the officer engaged in reckless disregard of the truth. Morris v. Lanpher; #08-2040, 2009 U.S. App. Lexis 8687 (8th Cir.).

Sexual Orientation Discrimination

     Two lesbian women claimed that the city failed to treat complaints they file in the same manner as those filed by heterosexuals, in violation of their equal protection rights and in retaliation for their exercise of their First Amendment rights in filing the complaints. They reported that a registered sex offender was violating the law by living near a school and also complained that they faced harassment by certain persons on the basis of their sexual orientation. While the municipal defendants were aware of the plaintiffs' sexual orientation, the court found no evidence of discriminatory intent on the basis of sexual orientation in the decisions not to pursue the complaints. Additionally, there was no evidence that the city's alleged non-responsiveness was motivated by retaliation against the plaintiffs for filing their reports, in violation of their First Amendment rights. Butler v. City of Batavi, #08-1361, 2009 U.S. App. Lexis 7229 (Unpub. 2nd Cir.).

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     Arrests: The Alameda County District Attorney's Office has prepared a 22-page article on the law of arrests, including the rules for making warrantless arrests, obtaining arrest warrants, and various procedural and post-arrest requirements.

     Exclusionary rule: "The Roberts Court and the Future of the Exclusionary Rule," by Susan A. Bandes (Apr. 2009).

     Interrogation: "Avoiding Sixth Amendment Suppression," by Kenneth A. Myers, 78 FBI Law Enforcement Bulletin Number 3, pgs. 23-31 (March 2009). "Officers must distinguish the protections of the Sixth Amendment with the right to counsel under the Fifth Amendment's privilege."

     Statistics: Indicators of School Crime and Safety: 2008. Presents data on crime and safety at school from the perspectives of students, teachers, principals, and the general population. A joint effort by the Bureau of Justice Statistics and the National Center for Education Statistics, this annual report examines crime occurring in school as well as on the way to and from school. It also provides the most current detailed statistical information on the nature of crime in schools, school environments, and responses to violence and crime at school. Data are drawn from several federally funded collections including the National Crime Victimization Survey, Youth Risk Behavior Survey, School Survey on Crime and Safety, and School and Staffing Survey. Information was gathered from an array of sources including: - National Crime Victimization Survey (NCVS) (1992-2006) - School Crime Supplement to the National Crime Victimization Survey (1995, 1991, 2001, 2003, 2005, and 2007) - Youth Risk Behavior Survey (1993, 1995, 1997, 1999, 2001, 2003, 2005, and 2007) - School Survey on Crime and Safety (1999-2000, 2003-04, and 2005-06) - School and Staffing Survey (1993-94, 1999-2000, and 2003-04). Highlights include the following: In 2006, among students ages 12–18, there were about 1.7 million victims of nonfatal crimes at school, including 909,500 thefts and 767,000 violent crimes (simple assault and serious violent crime). In 2007, 8 percent of students in grades 9–12 reported being threatened or injured with a weapon in the previous 12 months, and 22 percent reported that illegal drugs were made available to them on school property. During the 2005–06 school year, 86 percent of public schools reported that at least one violent crime, theft, or other crime occurred at their school. 04/09 NCJ 226343. Acrobat file (1.85M) | ASCII file (217K) | Spreadsheets (zip format 87K).

     Technology: High-Priority Criminal Justice Technology Needs, National Institute of Justice, U.S. Department of Justice. (2009).

     Terrorism: "Terrorism Prevention," by William McCormack, 78 FBI Law Enforcement Bulletin Number 3, pgs 1-7 (March 2009). "All law enforcement agencies play an important role in thwarting heinous acts of terrorism."

     Terrorism: The FBI's Terrorist Watchlist Nomination Practices, U.S. Department of Justice, Office of the Inspector General, Audit Division, May 2009.

     • Abbreviations of Law Reports, laws and agencies used in our publications.

     • AELE's list of recently-noted civil liability law resources.