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4th Circuit Haikus: Search & Seizure Update

Having trouble keeping up with the 4th Circuit’s binding precedent? The Op Shop is here to help, with the court’s published opinions paraphrased to the size of a haiku poem. This edition covers recent Fourth Amendment rulings.


Bags full of gun parts

Justified forensic search

Of a smuggler’s phone.

– United States v. Kolsuz (May 18, 2018)

To suppress statements

In civil deportations,

Show “egregious” acts.

– Sanchez v. Sessions (Mar. 27, 2018)

Forget the warrant:

Compelled masturbation was


– Sims v. Labowitz (Mar. 14, 2018)

ANYONE might drive

Used cars, with spare clothes and food.

At night. Nervously.

– United States v. Bowman (Mar. 1, 2018)

Handcuffing children

Who pose no objective threat

Is excessive force.

– E.W. v. Dolgos (Feb. 12, 2018)

With a search warrant

Issued in good faith, the state

Can probe the dark web.

– United States v. McLamb (Jan. 25, 2018)