text: On November 20, 1789, New Jersey ratified eleven of the twelve amendments, including the Fourth. On December 19, 1789, December 22, 1789, and January 19, 1790, respectively, Maryland, North Carolina, and South Carolina ratified all twelve amendments. On January 25 and 28, 1790, respectively, New Hampshire and Delaware ratified eleven of the Bill's twelve amendments, including the Fourth. This brought the total of ratifying states to six of the required ten, but the process stalled in other states: Connecticut and Georgia found a Bill of Rights unnecessary and so refused to ratify, while Massachusetts ratified most of the amendments, but failed to send official notice to the Secretary of State that it had done so (all three states would later ratify the Bill of Rights for sesquicentennial celebrations in 1939).


title: Fourth Amendment to the United States Constitution

text: In February through June 1790, New York, Pennsylvania, and Rhode Island each ratified eleven of the amendments, including the Fourth. Virginia initially postponed its debate, but after Vermont was admitted to the Union in 1791, the total number of states needed for ratification rose to eleven. Vermont ratified on November 3, 1791, approving all twelve amendments, and Virginia finally followed on December 15, 1791. Secretary of State Thomas Jefferson announced the adoption of the ten successfully ratified amendments on March 1, 1792.


text: The Fourth Amendment, and the personal rights which it secures, have a long history. The Bill of Rights originally restricted only the federal government, and went through a long initial phase of "judicial dormancy;" in the words of historian Gordon S. Wood, "After ratification, most Americans promptly forgot about the first ten amendments to the Constitution." Federal jurisdiction regarding criminal law was narrow until the late 19th century when the Interstate Commerce Act and Sherman Antitrust Act were passed. As federal criminal jurisdiction expanded to include other areas such as narcotics, more questions about the Fourth Amendment came to the U.S. Supreme Court. The Supreme Court responded to these questions by stating on the one hand that the government powers to search and seizure are limited by the Fourth Amendment so that arbitrary and oppressive interference by enforcement officials with the privacy and personal security of individuals are prevented and by outlining on the other hand the fundamental purpose of the amendment as guaranteeing "the privacy, dignity and security of persons against certain arbitrary and invasive acts by officers of the Government, without regard to whether the government actor is investigating crime or performing another function". To protect personal privacy and dignity against unwarranted intrusion by the State is the overriding function of the Fourth Amendment according to the Court in "Schmerber v. California" (1966), because "[t]he security of one's privacy against arbitrary intrusion by the police" is "at the core of the Fourth Amendment" and "basic to a free society." Pointing to historic precedents like "Entick v Carrington" (1765) and "Boyd v. United States" (1886), the Supreme Court held in "Silverman v. United States" (1961) that the Fourth Amendments core is the right to retreat into his own home and there be free from unreasonable governmental intrusion. With a view to "Camara v. Municipal Court" (1967) the Supreme Court observed in "Torres v. Madrid" (2021) that the focus of the Fourth Amendment is the privacy and security of individuals, not the particular manner of arbitrary invasion by governmental officials. In "Mapp v. Ohio" (1961), the Supreme Court ruled that the Fourth Amendment applies to the states by way of the Due Process Clause of the Fourteenth Amendment.


text: Fourth Amendment case law deals with three central issues: what government activities constitute "search" and "seizure;" what constitutes probable cause for these actions; how violations of Fourth Amendment rights should be addressed.


text: "The Fourth Amendment search and seizure doctrine involves a complex compromise between public safety and the constitutional right to personal liberty." The Fourth Amendment typically requires "a neutral and detached authority interposed between the police and the public", and it is offended by "general warrants" and laws that allow searches to be conducted "indiscriminately and without regard to their connection with [a] crime under investigation", for the "basic purpose of the Fourth Amendment, which is enforceable against the States through the Fourteenth, through its prohibition of 'unreasonable' searches and seizures is to safeguard the privacy and security of individuals against arbitrary invasions by governmental officials."


text: The Fourth Amendment has been held to mean that a search or an arrest generally requires a judicially sanctioned warrant, because the basic rule under the Fourth Amendment is that arrests and "searches conducted outside the judicial process, without prior approval by judge or magistrate, are "per se" unreasonable". In order for such a warrant to be considered reasonable, it must be supported by probable cause and be limited in scope according to specific information supplied by a person (usually a law enforcement officer) who has sworn by it and is therefore accountable to the issuing court. The Supreme Court further held in "Chandler v. Miller" (1997): "To be reasonable under the Fourth Amendment, a search ordinarily must be based on individualized suspicion of wrongdoing. But particularized exceptions to the main rule are sometimes warranted based on 'special needs, beyond the normal need for law enforcement'. ... When such 'special needs' are alleged, courts must undertake a context-specific inquiry, examining closely the competing private and public interests advanced by the parties." The amendment applies to governmental searches and seizures, but not those done by private citizens or organizations who are not acting on behalf of a government. In "Ontario v. Quon" (2010), the Court applied the amendment to a municipal government in its capacity as an employer, ruling that the City of Ontario had not violated the Fourth Amendment rights of city police officers by obtaining from the communications company and reviewing transcripts of text messages sent using government-provided pagers.


text: One threshold question in the Fourth Amendment jurisprudence is whether a "search" has occurred. Initial Fourth Amendment case law hinged on a citizen's property rights—that is, when the government physically intrudes on "persons, houses, papers, or effects" for the purpose of obtaining information, a "search" within the original meaning of the Fourth Amendment has occurred. Early 20th-century Court decisions, such as "Olmstead v. United States" (1928), held that Fourth Amendment rights applied in cases of physical intrusion, but not to other forms of police surveillance (e.g., wiretaps). In "Silverman v. United States" (1961), the Court stated of the amendment that "at the very core stands the right of a man to retreat into his own home and there be free from unreasonable governmental intrusion".


text: Fourth Amendment protections expanded significantly with "Katz v. United States" (1967). In "Katz", the Supreme Court expanded that focus to embrace an individual's right to privacy, and ruled that a search had occurred when the government wiretapped a telephone booth using a microphone attached to the outside of the glass. While there was no physical intrusion into the booth, the Court reasoned that: 1) Katz, by entering the booth and shutting the door behind him, had exhibited his expectation that "the words he utters into the mouthpiece will not be broadcast to the world"; and 2) society believes that his expectation was reasonable. Justice Potter Stewart wrote in the majority opinion that "the Fourth Amendment protects people, not places". A "search" occurs for purposes of the Fourth Amendment when the government violates a person's "reasonable expectation of privacy". Katz's reasonable expectation of privacy thus provided the basis to rule that the government's intrusion, though electronic rather than physical, was a search covered by the Fourth Amendment, and thus necessitated a warrant. The Court said it was not recognizing any general right to privacy in the Fourth Amendment, and that this wiretap could have been authorized if proper procedures had been followed.


text: This decision in "Katz" was later developed into the now commonly used two-prong test, adopted in "Smith v. Maryland" (1979), for determining whether a search has occurred for purposes of the Fourth Amendment:


text: The Supreme Court has held that the Fourth Amendment does not apply to information that is voluntarily shared with third parties. In "Smith", the Court held individuals have no "legitimate expectation of privacy" regarding the telephone numbers they dial because they knowingly give that information to telephone companies when they dial a number. However, under "Carpenter v. United States" (2018), individuals have a reasonable expectation of privacy under the Fourth Amendment regarding cell phone records even though they themselves turned over that information to "third parties" (i.e. the cell phone companies). Prior to the Carpenter ruling, law enforcement was able to retrieve cell site location information (CSLI) that included where a cell phone user had traveled over many months and with which other cell phone users they had associated. Carpenter v. United States serves as a landmark case because it slightly narrowed the Third Party Doctrine, thus requiring law enforcement to first obtain a search warrant before receiving CSLI records. "In the 5-4 [Carpenter] decision, the Court ruled 'narrowly' in favor of privacy, finding the government had constitutionally violated Mr. Carpenter's reasonable expectation of privacy by acquiring this private information without a warrant."


text: Following "Katz", the vast majority of Fourth Amendment search cases have turned on the right to privacy, but in "United States v. Jones" (2012), the Court ruled that the "Katz" standard did not replace earlier case law, but rather, has supplemented it. In "Jones", law enforcement officers had attached a GPS device on a car's exterior without Jones' knowledge or consent. The Court concluded that Jones was a bailee to the car, and so had a property interest in the car. Therefore, since the intrusion on the vehicle—a common law trespass—was for the purpose of obtaining information, the Court ruled that it was a search under the Fourth Amendment. The Court used similar "trespass" reasoning in "Florida v. Jardines" (2013), to rule that bringing a drug detection dog to sniff at the front door of a home was a search.


text: In certain situations, law enforcement may perform a search when they have a reasonable suspicion of criminal activity, even if it falls short of probable cause necessary for an arrest. Under "Terry v. Ohio" (1968), law enforcement officers are permitted to conduct a limited warrantless search on a level of suspicion less than probable cause under certain circumstances. In "Terry", the Supreme Court ruled that when a police officer witnesses "unusual conduct" that leads the officer to reasonably believe "that criminal activity may be afoot", that the suspicious person has a weapon "and" that the person is presently dangerous to the officer or others, the officer may conduct a pat-down search ("frisk" the person) to determine whether the person is carrying a weapon. This detention and search is known as a "Terry" stop. To conduct a frisk, officers must be able to point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant their actions. As established in "Florida v. Royer" (1983), such a search must be temporary, and questioning must be limited to the purpose of the stop (e.g., officers who stop a person because they have reasonable suspicion to believe the person was driving a stolen car, cannot, after confirming it is not stolen, compel the person to answer questions about anything else, such as contraband).


text: The Fourth Amendment proscribes unreasonable seizure of any person, person's home (including its curtilage) or personal property without a warrant. A seizure of property occurs when there is "some meaningful interference with an individual's possessory interests in that property," such as when police officers take personal property away from an owner to use as evidence, or when they participate in an eviction. The amendment also protects against unreasonable seizure of persons, including a brief detention.


text: A seizure does not occur just because the government questions an individual in a public place. The exclusionary rule would not bar voluntary answers to such questions from being offered into evidence in a subsequent criminal prosecution. The person is not being seized if his freedom of movement is not restrained. The government may not detain an individual even momentarily without reasonable, objective grounds, with few exceptions. His refusal to listen or answer does not by itself furnish such grounds.


text: In "United States v. Mendenhall" (1980), the Court held that a person is seized only when, by means of physical force "or" show of authority, his freedom of movement is restrained and, in the circumstances surrounding the incident, a reasonable person would believe he was not free to leave. Under "Torres v. Madrid" (2021), a person is considered to be seized following the use of physical force with the intent to restrain, even if the person manages to escape. In "Florida v. Bostick" (1991), the Court ruled that as long as the police do not convey a message that compliance with their requests is required, the police contact is a "citizen encounter" that falls outside the protections of the Fourth Amendment. If a person remains free to disregard questioning by the government, there has been no seizure and therefore no intrusion upon the person's privacy under the Fourth Amendment.


text: When a person is arrested and taken into police custody, he has been seized (i.e., a reasonable person who is handcuffed and placed in the back of a police car would not think they were free to leave). A person subjected to a routine traffic stop on the other hand, has been seized, but is not "arrested" because traffic stops are a relatively brief encounter and are more analogous to a "Terry" stop than to a formal arrest. If a person is not under suspicion of illegal behavior, a law enforcement official is not allowed to place an individual under arrest simply because this person does not wish to state his identity, provided specific state regulations do not specify this to be the case. A search incidental to an arrest that is not permissible under state law does not violate the Fourth Amendment, so long as the arresting officer has probable cause. In "Maryland v. King" (2013), the Court upheld the constitutionality of police swabbing for DNA upon arrests for serious crimes, along the same reasoning that allows police to take fingerprints or photographs of those they arrest and detain.


text: The government may not detain an individual even momentarily without reasonable and articulable suspicion, with a few exceptions. In "Delaware v. Prouse" (1979), the Court ruled an officer has made an illegal seizure when he stops an automobile and detains the driver in order to check his driver's license and the registration of the automobile, because the officer does not have articulable and reasonable suspicion that a motorist is unlicensed or that an automobile is not registered, or either the vehicle or an occupant is otherwise subject to seizure for violation of law.


text: Where society's need is great, no other effective means of meeting the need is available, and intrusion on people's privacy is minimal, certain discretionless checkpoints toward that end may briefly detain motorists. In "United States v. Martinez-Fuerte" (1976), the Supreme Court allowed discretionless immigration checkpoints. In "Michigan Dept. of State Police v. Sitz" (1990), the Supreme Court allowed discretionless sobriety checkpoints. In "Illinois v. Lidster" (2004), the Supreme Court allowed focused informational checkpoints. However, in "City of Indianapolis v. Edmond" (2000), the Supreme Court ruled that discretionary checkpoints or general crime-fighting checkpoints are not allowed.


text: Under the Fourth Amendment, law enforcement must receive written permission from a court of law, or otherwise qualified magistrate, to lawfully search and seize evidence while investigating criminal activity. A court grants permission by issuing a writ known as a warrant. A search or seizure is generally unreasonable and unconstitutional if conducted without a valid warrant and the police must obtain a warrant whenever practicable. Searches and seizures without a warrant are not considered unreasonable if one of the specifically established and well-delineated exceptions to the warrant requirement applies. These exceptions apply "[o]nly in those exceptional circumstances in which special needs, beyond the normal need for law enforcement, make the warrant and probable cause requirement impracticable."


text: In these situations where the warrant requirement doesn't apply a search or seizure nonetheless must be justified by some individualized suspicion of wrongdoing. However, the U.S. Supreme Court carved out an exception to the requirement of individualized suspicion. It ruled that, "In limited circumstances, where the privacy interests implicated by the search are minimal and where an important governmental interest furthered by the intrusion would be placed in jeopardy by a requirement of individualized suspicion" a search [or seizure] would still be reasonable.


text: The standards of probable cause differ for an arrest and a search. The government has probable cause to make an arrest when "the facts and circumstances within their knowledge and of which they had reasonably trustworthy information" would lead a prudent person to believe the arrested person had committed or was committing a crime. Probable cause to arrest must exist before the arrest is made. Evidence obtained after the arrest may not apply retroactively to justify the arrest.


text: When police conduct a search, the amendment requires that the warrant establish probable cause to believe the search will uncover criminal activity or contraband. They must have legally sufficient reasons to believe a search is necessary. In "Carroll v. United States" (1925), the Supreme Court stated that probable cause to search is a flexible, common-sense standard. To that end, the Court ruled in "Dumbra v. United States" (1925) that the term probable cause means "less than evidence that would justify condemnation," reiterating "Carroll"s assertion that it merely requires that the facts available to the officer would "warrant a man of reasonable caution" in the belief that specific items may be contraband or stolen property or useful as evidence of a crime. It does not demand any showing that such a belief be correct or more likely true than false. A "practical, non-technical" probability that incriminating evidence is involved is all that is required. In "Illinois v. Gates" (1983), the Court ruled that the reliability of an informant is to be determined based on the "totality of the circumstances."


text: If a party gives consent to a search, a warrant is not required. There are exceptions and complications to the rule, including the scope of the consent given, whether the consent is voluntarily given, and whether an individual has the right to consent to a search of another's property. In "Schneckloth v. Bustamonte" (1973), the Court ruled that a consent search is still valid even if the police do not inform a suspect of his right to refuse the search. This contrasts with Fifth Amendment rights, which cannot be relinquished without an explicit "Miranda" warning from police.


text: The Court stated in "United States v. Matlock" (1974) that a third party co-occupant could give consent for a search without violating a suspect's Fourth Amendment rights. However, in "Georgia v. Randolph" (2006), the Supreme Court ruled that when two co-occupants are both present, one consenting and the other rejecting the search of a shared residence, the police may not make a search of that residence within the consent exception to the warrant requirement. Per the Court's ruling in "Illinois v. Rodriguez" (1990), a consent search is still considered valid if police accept in good faith the consent of an "apparent authority," even if that party is later discovered to not have authority over the property in question. A telling case on this subject is "Stoner v. California", in which the Court held that police officers could not rely in good faith upon the apparent authority of a hotel clerk to consent to the search of a guest's room.


text: According to the plain view doctrine as defined in "Coolidge v. New Hampshire" (1971), if an officer is lawfully present, he may seize objects that are in "plain view." However, the officer must have had probable cause to believe the objects are contraband. What's more, the criminality of the object in plain view must be obvious by its very nature. In "Arizona v. Hicks", the Supreme Court held that an officer stepped beyond the plain view doctrine when he moved a turntable in order to view its serial number to confirm that the turntable was stolen. "A search is a search," proclaimed the Court, "even if it happens to disclose nothing but the bottom of a turntable."


text: Similarly, "open fields" such as pastures, open water, and woods may be searched without a warrant, on the ground that conduct occurring therein would have no reasonable expectation of privacy. The doctrine was first articulated by the Court in "Hester v. United States" (1924), which stated that "the special protection accorded by the Fourth Amendment to the people in their 'persons, houses, papers, and effects' is not extended to the open fields."


text: In "Oliver v. United States" (1984), the police ignored a "no trespassing" sign and a fence, trespassed onto the suspect's land without a warrant, followed a path for hundreds of feet, and discovered a field of marijuana. The Supreme Court ruled that no search had taken place, because there was no privacy expectation regarding an open field:


text: While open fields are not protected by the Fourth Amendment, the curtilage, or outdoor area immediately surrounding the home, is protected. Courts have treated this area as an extension of the house and as such subject to all the privacy protections afforded a person's home (unlike a person's open fields) under the Fourth Amendment. The curtilage is "intimately linked to the home, both physically and psychologically", and is where "privacy expectations are most heightened." However, courts have held aerial surveillance of curtilage not to be included in the protections from unwarranted search so long as the airspace above the curtilage is generally accessible by the public. An area is curtilage if it "harbors the intimate activity associated with the sanctity of a man's home and the privacies of life." Courts make this determination by examining "whether the area is included within an enclosure surrounding the home, the nature of the uses to which the area is put, and the steps taken by the resident to protect the area from observation by people passing by." The Court has acknowledged that a doorbell or knocker is typically treated as an invitation, or license, to the public to approach the front door of the home to deliver mail, sell goods, solicit for charities, etc. This license extends to the police, who have the right to try engaging a home's occupant in a "knock and talk" for the purpose of gathering evidence without a warrant. However, they cannot bring a drug detection dog to sniff at the front door of a home without either a warrant or consent of the homeowner or resident.


text: Law enforcement officers may also conduct warrantless searches in several types of exigent circumstances where obtaining a warrant is dangerous or impractical. Under "Terry v. Ohio" (1968) police are permitted to frisk suspects for weapons. The Court also allowed a search of arrested persons in "Weeks v. United States" (1914) to preserve evidence that might otherwise be destroyed and to ensure suspects were disarmed. In "Carroll v. United States" (1925), the Court ruled that law enforcement officers could search a vehicle that they suspected of carrying contraband without a warrant. The Court allowed blood to be drawn without a warrant from drunk-driving suspects in "Schmerber v. California" (1966) on the grounds that the time to obtain a warrant would allow a suspect's blood alcohol content to reduce, although this was later modified by "Missouri v. McNeely" (2013). "Warden v. Hayden" (1967) provided an exception to the warrant requirement if officers were in "hot pursuit" of a suspect.


text: The Supreme Court has held that individuals in automobiles have a reduced expectation of privacy, because (1) vehicles generally do not serve as residences or repositories of personal effects, and (2) vehicles "can be quickly moved out of the locality or jurisdiction in which the warrant must be sought." Vehicles may not be randomly stopped and searched; there must be probable cause or reasonable suspicion of criminal activity. Items in plain view may be seized; areas that could potentially hide weapons may also be searched. With probable cause to believe evidence is present, police officers may search any area in the vehicle. However, they may not extend the search to the vehicle's passengers without probable cause to search those passengers or consent from the passengers. In "Collins v. Virginia" (2018), the Court ruled that the motor vehicle exception did not apply to searches of vehicles parked within a residence's curtilage.


text: In "Arizona v. Gant" (2009), the Court ruled that a law enforcement officer needs a warrant before searching a motor vehicle after an arrest of an occupant of that vehicle, unless 1) at the time of the search the person being arrested is unsecured and within reaching distance of the passenger compartment of the vehicle or 2) police officers have reason to believe evidence for the crime for which the person is being arrested will be found in the vehicle.


text: A common law rule from Great Britain permits searches incident to an arrest without a warrant. This rule has been applied in American law, and has a lengthy common law history. The justification for such a search is to prevent the arrested individual 1.) from destroying evidence or 2.) using a weapon against the arresting officer by disarming the suspect. The U.S. Supreme Court ruled that "both justifications for the search-incident-to-arrest exception are absent and the rule does not apply" when "there is no possibility" the suspect could gain access to a weapon or destroy evidence. In "Trupiano v. United States" (1948), the Supreme Court held that "a search or seizure without a warrant as an incident to a lawful arrest has always been considered to be a strictly limited right. It grows out of the inherent necessities of the situation at the time of the arrest. But there must be something more in the way of necessity than merely a lawful arrest." In "United States v. Rabinowitz" (1950), the Court reversed "Trupiano", holding instead that the officers' opportunity to obtain a warrant was not germane to the reasonableness of a search incident to an arrest. "Rabinowitz" suggested that any area within the "immediate control" of the arrestee could be searched, but it did not define the term. In deciding "Chimel v. California" (1969), the Supreme Court elucidated its previous decisions. It held that when an arrest is made, it is reasonable for the officer to search the arrestee for weapons and evidence. However, in "Riley v. California" (2014), the Supreme Court ruled unanimously that police must obtain a warrant to search an arrestee's cellular phone. The Court said that earlier Supreme Court decisions permitting searches incident to an arrest without a warrant do not apply to "modern cellphones, which are now such a pervasive and insistent part of daily life that the proverbial visitor from Mars might conclude they were an important feature of human anatomy," and noted that U.S. citizens' cellphones today typically contain "a digital record of nearly every aspect of their lives—from the mundane to the intimate."


text: Searches conducted at the United States border or the equivalent of the border (such as an international airport) may be conducted without a warrant or probable cause subject to the border search exception. Most border searches may be conducted entirely at random, without any level of suspicion, pursuant to U.S. Customs and Border Protection plenary search authority. However, searches that intrude upon a traveler's personal dignity and privacy interests, such as strip and body cavity searches, must be supported by "reasonable suspicion". The U.S. Courts of Appeals for the Fourth and Ninth circuits have ruled that information on a traveler's electronic materials, including personal files on a laptop computer, may be searched at random, without suspicion.


text: The Supreme Court decision in "United States v. U.S. District Court" (1972) left open the possibility for a foreign intelligence surveillance exception to the warrant clause. Three United States Courts of Appeals have recognized a foreign intelligence surveillance exception to the warrant clause, but tied it to certain requirements. The exception to the Fourth Amendment was formally recognized by the United States Foreign Intelligence Surveillance Court of Review in its 2008 "In re Directives" decision. The lower court held that "a foreign intelligence exception to the Fourth Amendment's warrant requirement exists when surveillance is conducted to obtain foreign intelligence for national security purposes and is directed against foreign powers or agents of foreign powers reasonably believed to be located outside the United States."


text: Despite the foregoing citation the Fourth Amendment prohibitions against unreasonable searches and seizures nonetheless apply to the contents of all communications, whatever the means, because, "a person's private communications are akin to personal papers." Fourth Amendment reasonableness is the point at which the United States government's interest advanced by a particular search or seizure outweighs the loss of individual privacy or freedom of movement that attends the government's action. The United Supreme Court said in "Board of Education v. Earls" (2002) when 'special needs', beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable the reasonableness of a search is determined by balancing the nature of the intrusion on the individual's privacy against the promotion of legitimate governmental interests. Additionally in "Illinois v. Lidster" (2004) the Court explained in judging reasonableness it looks to "the gravity of the public concerns served by the seizure, the degree to which the seizure advances the public interest, and the severity of the interference with individual liberty". To protect the telecommunication carriers cooperating with the U.S. government from legal action, the Congress passed a bill updating the Foreign Intelligence Surveillance Act of 1978 to permit this type of surveillance.


text: In "New Jersey v. T. L. O." (1985), the Supreme Court ruled that searches in public schools do not require warrants, as long as the searching officers have reasonable grounds for believing the search will result in finding evidence of illegal activity. Similarly, in "Samson v. California" (2006), the Court ruled that government offices may be searched for evidence of work-related misconduct by government employees on similar grounds. Searches of prison cells are subject to no restraints relating to reasonableness or probable cause. However, in "Safford Unified School District v. Redding" (2009), the Court ruled that school officials violated the Fourth Amendment when they strip searched a student based only on another student's claiming to have received drugs from her.


text: One way courts enforce the Fourth Amendment is through the use of the exclusionary rule. The rule provides that evidence obtained through a violation of the Fourth Amendment is generally not admissible by the prosecution during the defendant's criminal trial. The Court stated in "Elkins v. United States" (1960) that the rule's function "is to deter—to compel respect for the constitutional guaranty in the only effectively available way—by removing the incentive to disregard it."


text: The Court adopted the exclusionary rule in "Weeks v. United States" (1914), prior to which all evidence, no matter how seized, could be admitted in court. In "Silverthorne Lumber Co. v. United States" (1920) and "Nardone v. United States" (1939), the Court ruled that leads or other evidence resulting from illegally obtained evidence are also inadmissible in trials. Justice Felix Frankfurter described this secondary evidence in the "Nardone" decision as the "fruit of the poisonous tree". The Supreme Court rejected incorporating the exclusionary rule by way of the Fourteenth Amendment in "Wolf v. Colorado" (1949), but "Wolf" was explicitly overruled in "Mapp v. Ohio" (1961), making the Fourth Amendment (including the exclusionary rule) applicable in state proceedings.


text: The exclusionary rule and its effectiveness have often been controversial, particularly since its 1961 application to state proceedings. Critics charge that the rule hampers police investigation and can result in freeing guilty parties convicted on reliable evidence; other critics say the rule has not been successful in deterring illegal police searches. Proponents argue that the number of criminal convictions overturned under the rule has been minimal and that no other effective mechanism exists to enforce the Fourth Amendment. In 1982, California passed a "Victim's Bill of Rights" containing a provision to repeal the exclusionary rule; though the bill could not affect federally mandated rights under the Fourth Amendment, it blocked the state courts from expanding these protections further.


text: Since 1974, the Supreme Court has repeatedly limited the exclusionary rule. In "United States v. Calandra" (1974), the Court ruled that grand juries may use illegally obtained evidence when questioning witnesses, because "the damage to that institution from the unprecedented extension of the exclusionary rule outweighs the benefit of any possible incremental deterrent effect." Explaining the purpose of the rule, the Court said the rule "is a judicially created remedy designed to safeguard Fourth Amendment rights generally through its deterrent effect, rather than a personal constitutional right of the party aggrieved."


text: In "Arizona v. Evans" (1995) and "Herring v. United States" (2009), the Court ruled that the exclusionary rule does not apply to evidence found due to negligence regarding a government database, as long as the arresting police officer relied on that database in "good faith" and the negligence was not pervasive. In "Davis v. United States" (2011), the Court ruled that the exclusionary rule does not apply to a Fourth Amendment violation resulting from a reasonable reliance on binding appellate precedent. In "Utah v. Strieff" (2016), the Court ruled that evidence obtained from an unlawful police stop would not be excluded from court when the link between the stop and the evidence's discovery was "attenuated" by the discovery of an outstanding warrant during the stop.


text: On December 16, 2013, in "Klayman v. Obama", a United States district court ruled that the mass collection of metadata of Americans' telephone records by the National Security Agency probably violates the Fourth Amendment. The court granted a preliminary injunction, blocking the collection of phone data for two private plaintiffs and ordered the government to destroy any of their records that have been gathered. The court stayed the ruling pending a government appeal, recognizing the "significant national security interests at stake in this case and the novelty of the constitutional issues."


text: However, in "ACLU v. Clapper", a United States district court ruled that the U.S. government's global telephone data-gathering system is needed to thwart potential terrorist attacks, and that it can work only if everyone's calls are included. The court also ruled that Congress legally set up the program and it does not violate anyone's constitutional rights. The court concluded that the telephone data being swept up by NSA did not belong to telephone users, but to the telephone companies. Also, the court held that when NSA obtains such data from the telephone companies, and then probes into it to find links between callers and potential terrorists, this further use of the data was not even a search under the Fourth Amendment, concluding that the controlling precedent is "Smith v. Maryland", saying "Smith's bedrock holding is that an individual has no legitimate expectation of privacy in information provided to third parties." The American Civil Liberties Union declared on January 2, 2014, that it will appeal the ruling that NSA bulk phone record collection is legal. "The government has a legitimate interest in tracking the associations of suspected terrorists, but tracking those associations does not require the government to subject every citizen to permanent surveillance," deputy ACLU legal director Jameel Jaffer said in a statement.


title: She's Out of My League

text: She's Out of My League is a 2010 American romantic comedy film directed by Jim Field Smith and written by Sean Anders and John Morris. It stars Jay Baruchel and Alice Eve, and was produced by Jimmy Miller and David Householter for Paramount Pictures and DreamWorks Pictures. It was filmed in Pittsburgh, Pennsylvania. Production finished in 2008, and it received wide theatrical release on March 12, 2010. It was Smith's first feature film as a director.


title: She's Out of My League

text: Kirk Kettner is a TSA agent at Pittsburgh International Airport. He attempts to reconcile with his ex-girlfriend Marnie, despite her treating him poorly. Meanwhile, an attractive and successful woman named Molly McCleish arrives at the terminal to board a flight. Kirk is the only TSA agent who does not flirt with or harass her, and saves her from his boss's unwanted advances. After boarding, she realizes she left her cell phone at security, and when her friend Patty calls it for her, Kirk answers. They arrange to meet the following day so he can return it.


title: She's Out of My League

text: The next evening, Kirk and his friend Devon arrive at the Andy Warhol Museum to return Molly's phone. Someone bumps into Kirk, causing him to spill his drink on the museum director. Thinking Kirk did it deliberately, the director tells him and Devon they must leave. As they leave the building, Molly follows them outside. Feeling badly about the misunderstanding, she offers Kirk tickets to a Pittsburgh Penguins hockey game. Kirk brings his friend Stainer to the game, where they meet Molly and her friend Patty. While Stainer and Molly are away from their seats, Patty tells Kirk that Molly is interested in him.


title: She's Out of My League

text: Molly asks Kirk out a few days later and he agrees. Stainer predicts that their relationship will fail—he considers Molly a "10" and Kirk a "5", and that the numerical "chasm" between them is too big. Meanwhile, Patty thinks Molly has chosen Kirk only because he is "safe" and won't hurt her. On their date, Kirk tells Molly that he dreams of being a pilot; and Molly tells him she almost became a lawyer before realizing her love for event planning. At the end of the night, they kiss in Kirk's car.


title: She's Out of My League

text: Molly accompanies Kirk to a family lunch, where she charms the men and makes Marnie jealous. After returning to Molly's apartment, while making out, Kirk ejaculates prematurely in his pants moments before Molly's parents unexpectedly arrive. Desperate to conceal the stain on his pants, Kirk won't stand to shake hands with Molly's dad, and leaves quickly. Believing he fled to avoid meeting her parents, Molly ignores Kirk's calls. Kirk tracks her down, embarrassingly explains why he had to go, and she forgives him.


title: She's Out of My League

text: At Molly's sister Katie's 21st birthday party, Kirk is troubled by Molly being intentionally vague about Kirk's line of work to her parents. Molly's ex-boyfriend Cam, a stunt pilot, then arrives and alludes to Molly having a physical defect. After the party, they return to Molly's apartment and partially undress. Kirk discovers Molly's "defect" is slightly webbed toes, which Kirk considers so minor that he decides that she is indeed too perfect for him. Upset with Kirk over his insecurities and wishing that there was something wrong with her to justify them being together, Molly confesses that Cam had the same problem. She admits she asked Kirk out because she considered him safe, causing Kirk to break up with her. Kirk resumes his relationship with Marnie and makes plans to attend a family vacation in Branson together.


title: She's Out of My League

text: Later, Stainer asks an ex-girlfriend of his if he was good enough for her, she tells him that his insecurities caused her to end their relationship. Realizing he caused Kirk and Molly's break-up by telling Kirk that Molly was too good for him, Stainer phones Patty and gets her to bring Molly to the airport. Stainer tries to get Kirk off the plane he has boarded, but to no avail. He has Jack stop the plane, causing everyone to have to de-board. Kirk flees from Marnie, who chases after him, and Kirk breaks up with her in the process. Kirk meets Molly at the terminal gate, where she confesses Kirk's insecurities about himself are justified, but that she wants to be with him regardless. They reconcile and resume their relationship. Later, Kirk surprises Molly with a mystery trip to Cleveland via small aircraft, revealing that he has fulfilled his dream of becoming a pilot.


title: She's Out of My League

text: Principal photography commenced on March 31, 2008 at the Mellon Arena, now the former home of the Pittsburgh Penguins hockey team. Filming continued in various locations around Pittsburgh until the end of May 2008, including the Pittsburgh International Airport, The Andy Warhol Museum, Mount Washington, the downtown Regional Enterprise Tower, PNC Park, Market Square, and Century III. Area sound stages were also used. Pluma's Restaurant in Irwin, Pennsylvania was used for bar scenes when shooting at Mellon Arena became impossible due to the Penguins' advancement to the 2008 Stanley Cup Finals. The film was co-produced by Jimmy Miller of Mosaic Media Group, a native of Castle Shannon, Pennsylvania and the brother of comedian Dennis Miller.


title: She's Out of My League

text: Molly's parents, Mr. and Mrs. McCleish, are played by Alice Eve's real-life parents, Sharon Maughan and Trevor Eve.


title: She's Out of My League

text: "She's Out of My League" grossed $32 million in North America and $17.8 million in other territories for a total gross of $49.8 million, against a budget of $20 million.


title: She's Out of My League

text: It opened at #3 at the box office, behind "Alice in Wonderland" and "Green Zone", with an estimated $9.6 million gross.


title: She's Out of My League

text: On Rotten Tomatoes, the film has an approval rating of 58% based on 133 reviews, with an average rating of 5.60/10. The site's critical consensus reads, ""She’s Out of My League" has moments of humor and insight, but it’s bogged down by excessive vulgarity and cartoonishness." On Metacritic the film has score of 46 out of 100, based on 29 critics, indicating "mixed or average reviews". Audiences polled by CinemaScore gave the film an average grade of "B" on a scale of A+ to F.


title: She's Out of My League

text: Critic Roger Ebert of the Chicago Sun-Times gave the film three stars out of four saying, "The movie is not a comedy classic. But in a genre where so many movies struggle to lift themselves from zero to one, it's about, oh, a six point five."


title: She's Out of My League

text: Peter Travers of "Rolling Stone" gave the film three stars out of four, commenting, "This R-rated blend of the sweet and the raunchy has its heart in the right place." Jake Tomlinson of "Shave Magazine" gave the movie four and a half stars out of five and praised the movie "for not throwing in cheap obstacles" and for the "good soundtrack."


title: She's Out of My League

text: Michael O'Sullivan of "The Washington Post" was less enthused, giving the film one star out of four: "The movie clearly aspires to rise to the smutty-but-sweet synergy of other, better films. But "She's Out of My League" can't touch them."


title: She's Out of My League

text: "She's Out of My League" was released on DVD and Blu-ray on June 22, 2010. As of October 2015, it has grossed $12.5 million in home video sales.


title: Robert Culp

text: Robert Martin Culp (August 16, 1930 – March 24, 2010) was an American actor widely known for his work in television. Culp earned an international reputation for his role as Kelly Robinson on "I Spy" (1965–1968), the espionage television series in which co-star Bill Cosby and he played secret agents. Before this, he starred in the CBS/Four Star Western series "Trackdown" as Texas Ranger Hoby Gilman in 71 episodes from 1957 to 1959. The 1980s brought him back to television as FBI Agent Bill Maxwell on "The Greatest American Hero". Later, he had a recurring role as Warren Whelan on "Everybody Loves Raymond". Culp gave hundreds of performances in a career spanning more than 50 years.


title: Robert Culp

text: Culp was born on August 16, 1930, in either Oakland, California, or Berkeley, California. He was the only child of Crozier Cordell Culp, an attorney, and his wife, Bethel Martin Culp (née Collins). He graduated from Berkeley High School, where he was a pole vaulter and took second place at the 1947 CIF California State Meet.


title: Robert Culp

text: Culp attended the University of the Pacific in Stockton, California, but did not graduate. He later attended Washington University in St. Louis, San Francisco State, and the University of Washington School of Drama, but never completed an academic degree. He received his acting training at HB Studio in New York City.


title: Robert Culp

text: Culp came to national attention early in his career as the star of the 1957–1959 CBS Western television series "Trackdown", in which he played Texas Ranger Hoby Gilman, based in the town of Porter, Texas. It was one of Culp's many appearances in TV Westerns. The pilot for "Trackdown" was "Badge of Honor", a 1956 episode of "Dick Powell's Zane Grey Theatre", in which Culp starred as Gilman.


title: Robert Culp

text: In 1960, he appeared in two more episodes of "Zane Grey Theatre", playing different roles in "Morning Incident" and "Calico Bait". After "Trackdown" ended in 1959 after two seasons, Culp continued to work in television, including a guest-starring role as Stewart Douglas in the 1960 episode "So Dim the Light" of CBS's anthology series "The DuPont Show with June Allyson". In the summer of 1960, he guest-starred on David McLean's NBC Western series "Tate".


title: Robert Culp

text: He played Clay Horne in the series finale, "Cave-In", of the CBS Western "Johnny Ringo", starring Don Durant. In 1961, Culp played the part of Craig Kern, a morphine-addicted soldier, in the episode "Incident on Top of the World" in the CBS series "Rawhide". About this time, Culp was cast on the NBC anthology series, "The Barbara Stanwyck Show" and in the NBC Civil War drama, "The Americans". Culp was cast as Captain Shark in a first-season episode of NBC's "The Man from U.N.C.L.E." (1964). Some of his more memorable performances were in three episodes of the science-fiction anthology series on "The Outer Limits" (1963–65), including the classic "Demon with a Glass Hand", written by Harlan Ellison. In the 1961 season, he guest-starred on the NBC's Western "Bonanza". In the 1961–62 season, he guest-starred on ABC's crime drama "" and that network's "The Rifleman." In the 1962–63 season, he guest-starred in NBC's modern Western series "Empire" starring Richard Egan.


title: Robert Culp

text: In 1964, Culp played Charlie Orwell, an alcoholic veterinarian, in an episode of "The Virginian" (NBC 1962–1971) titled "The Stallion". That same year, he appeared in yet another Western, "Gunsmoke". In the series' episode "Hung High", he portrays an outlaw named Joe Costa, who attempts to frame Matt Dillon for lynching a prisoner who had killed the marshal's friend. In 1965, he was cast as Frank Melo in "The Tender Twigs" of James Franciscus's NBC education drama series, "Mr. Novak".


title: Robert Culp

text: Culp then played perhaps his most memorable character, CIA secret agent Kelly Robinson, who operated undercover as a touring tennis professional, for three years on the hit NBC series "I Spy" (1965–1968), with co-star Bill Cosby. Culp wrote the scripts for seven episodes, one of which he also directed and an episode earned him an Emmy nomination for writing. For all three years of the series, he was also nominated for an acting Emmy (Outstanding Performance by an Actor in a Leading Role in a Dramatic Series category), but lost each time to Cosby.


title: Robert Culp

text: In 1968, Culp also made an uncredited cameo appearance as an inebriated Turkish waiter on "Get Smart", the spy-spoof comedy series, in an "I Spy" parody episode titled "Die Spy". In this, secret agent Maxwell Smart played by Don Adams in effect assumes Culp's Kelly Robinson character, as he pretends to be an international table-tennis champion. The episode faithfully recreates the "I Spy" theme music, montage graphics, and back-and-forth banter between Robinson and Scott, with actor/comedian Stu Gilliam imitating Cosby.


title: Robert Culp

text: In 1971, Culp, Peter Falk, Robert Wagner, and Darren McGavin each stepped in to take turns with Anthony Franciosa's rotation of NBC's series "The Name of the Game" after Franciosa was fired, alternating a lead role of the lavish, 90-minute show about the magazine business with Gene Barry and Robert Stack. Also in 1971, he portrayed an unemployed actor, the husband of ambitious Angie Dickinson, in the TV movie "See the Man Run". Culp played the murderer in three "Columbo" episodes ("Death Lends a Hand" in 1971, "The Most Crucial Game" in 1972, "Double Exposure" in 1973) and also appeared in the 1990 episode "Columbo Goes to College" as the father of one of two young murderers. He also played the murderer in the pilot episode of "Mrs. Columbo" starring Kate Mulgrew in the title role.


title: Robert Culp

text: In 1973, Culp almost took the male lead in the sci-fi television series "". During negotiations with creator and executive producer Gerry Anderson, Culp expressed himself to be not only an asset as an actor, but also as a director and producer for the proposed series. The part instead went to Martin Landau.


title: Robert Culp

text: Culp co-starred in "The Greatest American Hero" as tough veteran FBI Special Agent Bill Maxwell, who teams up with a high-school teacher who receives superpowers from extraterrestrials. He wrote and directed the second-season finale episode "Lilacs, Mr. Maxwell", with free rein to do the episode as he saw fit. The show lasted three years from 1981 to 1983. He reprised the role in the spin-off pilot "The Greatest American Heroine" and a voice-over on the stop-motion sketch comedy "Robot Chicken". During that time, Culp was rumored to replace Larry Hagman as J. R. Ewing in "Dallas." However, Culp firmly denied this, insisting he would never leave his role as Bill Maxwell. In 1987, he reunited with Cosby on "The Cosby Show", playing Dr. Cliff Huxtable's old friend Scott Kelly. The name was a combination of their "I Spy" characters' names.


title: Robert Culp

text: Culp had a recurring role on "Everybody Loves Raymond" as Warren Whelan, the father of Debra Barone and father-in-law of Ray Barone. He appeared on episodes of other television programs, including a 1961 season-three episode of "Bonanza" titled "Broken Ballad", as well as "The Golden Girls", "The Nanny", "The Girls Next Door", and "Wings". He was the voice of the character Halcyon Renard in the Disney adventure cartoon "Gargoyles".


title: Robert Culp

text: In "I Spy Returns" (1994), a nostalgic television movie, Culp and Cosby reprised their roles as Robinson and Scott for the first time since 1968. Culp and Cosby reunited one last time on the television show "Cosby" in an episode entitled "My Spy" (1999), in which Cosby's character, Hilton Lucas, dreams he is Alexander Scott on a mission with Kelly Robinson. Robert Culp also appeared on "Walker, Texas Ranger" as Lyle Pike in the episode "Trust No One" (February 18, 1995). In 1997, he played a CIA agent and the father of Dr. Jesse Travis on "Diagnosis Murder" along with Barbara Bain, Robert Vaughn, and Patrick Macnee.


title: Robert Culp

text: Culp worked as an actor in many theatrical films, beginning with three in 1963: As naval officer John F. Kennedy's good friend Ensign George Ross in "PT 109", as legendary gunslinger Wild Bill Hickok in "The Raiders", and as the debonair fiancé of Jane Fonda in "Sunday in New York".


title: Robert Culp

text: He starred in "Bob & Carol & Ted & Alice" in 1969, with Natalie Wood. Another memorable role came as another gunslinger, Thomas Luther Price, in "Hannie Caulder" (1971) opposite Raquel Welch. A year later, "Hickey & Boggs" reunited him with Cosby for the first time since "I Spy". Culp also directed this feature film, in which Cosby and he portray over-the-hill private eyes. In 1986, he had a primary role as General Woods in the comedy "Combat Academy". Culp played the U.S. President in Alan J. Pakula's 1993 murder mystery, "The Pelican Brief".


title: Robert Culp

text: Culp appeared in the 1993 live action video game "Voyeur" as the game's villain, industrialist/politician Reed Hawke. He lent his voice to the digital character Doctor Breen, the prime antagonist in the 2004 computer game "Half-Life 2". The video clip of "Guilty Conscience" features Culp as an erudite and detached narrator describing the scenes where Eminem and Dr. Dre rap lyrics against each other. He only appears in the music video. In the album version, the narrator is Mark Avery.


title: Robert Culp

text: On November 9, 2007, on "The O'Reilly Factor", host Bill O'Reilly interviewed Culp about the actor's career and awarded Culp with the distinction "TV Icon of the Week". Culp played Simon, Blanche's beau, in the episode "Like the Beep Beep Beep of My Tom Tom" when Blanche needs a pacemaker on "The Golden Girls".


title: Robert Culp

text: Culp wrote scripts for seven "I Spy" episodes, one of which he also directed. He later wrote and directed two episodes of "The Greatest American Hero", including the series finale. Culp also wrote scripts for other television series, including "Trackdown", a two-part episode from "The Rifleman", and "Cain's Hundred".


title: Robert Culp

text: Culp married five times and is the father of five children. With his second wife, Nancy Wilner, he had sons Joshua, Jason, and Joseph, and daughter Rachel. With his last wife, he had another daughter Samantha. Jason Culp is a voice actor who has narrated many audiobooks.


title: Robert Culp

text: Culp was married to French actress France Nguyen (known as France Nuyen), from 1967 to 1970, whom he met when she guest-starred on "I Spy". She appeared in four episodes, two of them written by Culp. Culp and Nuyen also co-hosted the second episode of the TV comedy "Turn-On" in 1969, but the program was never shown, as the series was cancelled after its first airing.


title: Robert Culp

text: On March 24, 2010, Culp, at age 79, died after a fall while on a walk near Runyon Canyon Park. He was buried at Sunset View Cemetery in El Cerrito. A memorial service was held at Grauman's Egyptian Theater in Los Angeles on April 10, 2010.


title: Robert Culp

text: At the time of his death, Culp had just completed performing a supporting role as Blakesley in the film "The Assignment". He was also working on several screenplays, including an adaptation of the story of "Terry and the Pirates" that had already been accepted for filming and was scheduled to start production in Hong Kong in 2012, with Culp directing. "Terry and the Pirates" had been Culp's favorite comic strip as a boy, and it was his long-time wish to make a film based on it.


title: Iwo Jima

text: Iwo Jima (, ), known in Japan as , is one of the Japanese Volcano Islands and lies south of the Bonin Islands. Together with other islands, they form the Ogasawara Archipelago. The highest point of Iwo Jima is Mount Suribachi at high.


title: Iwo Jima

text: Although south of the metropolis of Tokyo on the mainland, this island of 21 km (8 square miles) is administered as part of the Ogasawara Subprefecture of Tokyo. Since July 1944, when all the civilians were forcibly evacuated, the island has had a military-only population.


title: Iwo Jima

text: The island was the location of the Battle of Iwo Jima between February 1945 and March 1945. This engagement saw some of the fiercest fighting of the Pacific War, with each side suffering over 20,000 casualties in the battle. The island became globally recognized when Joe Rosenthal, of the Associated Press, published his photograph "Raising the Flag on Iwo Jima", taken on Mount Suribachi. The US military occupied Iwo Jima until 1968, when it was returned to Japan.


title: Iwo Jima

text: The first European to arrive at Iwo Jima was Spanish sailor Bernardo de la Torre who named it Sufre Island, after the old Spanish term for sulphur ("azufre" in modern Spanish). At that time Iwo Jima and other nearby islands represented boundaries between the Spanish and Portuguese Empires within the far East as the demarcation line of the Treaty of Zaragoza crossed the area.


title: Iwo Jima

text: In 1779, the island was charted as Sulphur Island, the literal translation of its official name, during Captain James Cook's third surveying voyage. As reported in the December 1786 supplement to "The New London Magazine" :


title: Iwo Jima

text: The name "Sulphur Island" was translated into Late Middle Japanese with the Sino-Japanese rendering "iwō-tō" イヲウトウ (, modern Japanese "Iō-tō" イオウトウ), from Middle Chinese "ljuw-huang" "sulfur" and "táw" "island". The historical spelling "iwautau" had come to be pronounced (approximately) "Iwō-tō" by the age of Western exploration, and the 1946 orthography reform fixed the spelling and pronunciation at "Iō-tō" イオウトウ.


title: Iwo Jima

text: An alternative, "Iwō-jima", modern "Iō-jima", also appeared in nautical atlases. ("Tō" and "shima" are different readings of the kanji for , the "shima" being changed by rendaku to "jima" in this case.) Japanese naval officers who arrived to fortify the island before the U.S. invasion mistakenly called it "Iwō-jima", and in this way, the "Iwo Jima" reading became mainstream and was the one used by U.S. forces who arrived during World War II. Former island residents protested against this rendering, and the Ministry of Land, Infrastructure, Transport and Tourism's Geographical Survey Institute debated the issue and formally announced on June 18, 2007, that the official Japanese pronunciation of the island's name would revert to the pre-war "Iō-tō". Moves to revert the pronunciation were sparked by the high-profile films "Flags of Our Fathers" and "Letters from Iwo Jima". The change does not affect how the name is written with kanji, , only how it is pronounced or written in hiragana, katakana and rōmaji.


title: Iwo Jima

text: The island has an approximate area of . The most prominent feature is Mount Suribachi on the southern tip, a vent that is thought to be dormant and is high. Named after a Japanese grinding bowl, the summit of Mount Suribachi is the highest point on the island. Iwo Jima is unusually flat and featureless for a volcanic island. Suribachi is the only obvious volcanic feature, as the island is only the resurgent dome (raised centre) of a larger submerged volcanic caldera surrounding the island. The island forms part of the Kazan-retto islands Important Bird Area (IBA), designated by BirdLife International.


title: Iwo Jima

text: 80 km (43 nautical miles, 50 mi) north of the island is and south is ; these three islands make up the Volcano Islands group of the Ogasawara Islands. Just south of Minami-Iō-jima are the Mariana Islands.


title: Iwo Jima

text: The visible island stands on a plateau (probably made by wave erosion) at depth about 15 m, which is the top of an underwater mountain 1.5 km to 2 km tall and 40 km diameter at base.


title: Iwo Jima

text: Iwo Jima has a history of minor volcanic activity a few times per year (fumaroles, and their resultant discolored patches of seawater nearby). In November 2015 Iwo Jima was placed first in a list of ten dangerous volcanoes, with volcanologists saying there was a one in three chance of a large eruption from one of the ten this century.


title: Iwo Jima

text: The island was first visited by a westerner in October 1543, by Spanish sailor Bernardo de la Torre on board the carrack "San Juan de Letrán" when trying to return from Sarangani to New Spain.


title: Iwo Jima

text: Before World War II Iwo Jima was administered as Iōjima village and was (and is today) part of Tokyo. A census in June 1943 reported an island civilian population of 1,018 (533 males, 485 females) in 192 households in six settlements. The island had a primary school, a Shinto shrine, and one police officer; it was serviced by a mail ship from Haha-jima once a month, and by Nippon Yusen ship once every two months. The island's economy relied upon sulfur mining, sugarcane farming, and fishing; an isolated island in the middle of the Pacific Ocean with poor economic prospects, Iwo Jima had to import all rice and consumer goods from the Home Islands.


title: Iwo Jima

text: Even before the beginning of World War II, there was a garrison of the Imperial Japanese Navy at the southern part of Iwo Jima. It was off-limits to the island's civilian population, who already had little contact with the naval personnel, except for trading.


title: Iwo Jima

text: Throughout 1944, Japan conducted a massive military buildup on Iwo Jima in anticipation of a U.S. invasion. In July 1944, the island's civilian population was forcibly evacuated, and no civilians have permanently settled on the island since.


title: Iwo Jima

text: The American invasion of Iwo Jima began on February 19, 1945, and continued to March 26, 1945. The battle was a major initiative of the Pacific Campaign of World War II. The Marine invasion, known as "Operation Detachment", was charged with the mission of capturing the airfields on the island for use by P-51 fighters, and rescue of damaged heavy bombers that were not able to reach their main bases at Guam and Saipan; until then Japanese warplanes from there had harried U.S. bombing missions to Tokyo.


title: Iwo Jima

text: The battle was marked by some of the fiercest fighting of the war. The Imperial Japanese Army positions on the island were heavily fortified, with vast bunkers, hidden artillery, and 18 kilometres (11 mi) of tunnels. The battle was the first U.S. attack on the Japanese Home Islands and the Imperial soldiers defended their positions tenaciously. Of the 21,000 Japanese soldiers present at the beginning of the battle, over 19,000 were killed and only 1,083 taken prisoner.


title: Iwo Jima

text: One of the first objectives after landing on the beachhead was the taking of Mount Suribachi. At the second raising of a flag on the peak, Joe Rosenthal photographed six Marines raising the United States flag on the fourth day of the battle (February 23).


title: Iwo Jima

text: The photograph was extremely popular, and won the Pulitzer Prize for Photography that same year. It is regarded as one of the most significant and recognizable images of the war.


title: Iwo Jima

text: After the fall of Mount Suribachi in the south, the Japanese still held a strong position throughout the island. General Tadamichi Kuribayashi still had the equivalent of eight infantry battalions, a tank regiment, two artillery, and three heavy mortar battalions, plus the 5,000 gunners and naval infantry. With the landing area secure, more troops and heavy equipment came ashore and the invasion proceeded north to capture the airfields and the remainder of the island. Most Japanese soldiers fought to the death. On the night of March 25, a 300-man Japanese force launched a final counterattack led by Kuribayashi. The island was officially declared "secured" the following morning.


title: Iwo Jima

text: According to the U.S. Navy, "The 36-day (Iwo Jima) assault resulted in more than 26,000 American casualties, including 6,800 dead." Comparatively, the 82-day Battle of Okinawa lasted from early April until mid-June 1945 and U.S. (five Army, two Marine Corps Divisions and Navy personnel on ships) casualties were over 62,000 of whom over 12,000 were killed or missing, while the Battle of the Bulge lasted 40 days (16 December 1944 – 25 January 1945) with almost 90,000 U.S. casualties comprising 19,000 killed, 47,500 wounded and 23,000 captured or missing.


title: Iwo Jima

text: After Iwo Jima was declared secured, about 3,000 Japanese soldiers were left alive in the island's warren of caves and tunnels. Those who could not bring themselves to commit suicide hid in the caves during the day and came out at night to prowl for provisions. Some did eventually surrender and were surprised that the Americans often received them with compassion – offering them water, cigarettes, or coffee. The last of these stragglers, two of Lieutenant Toshihiko Ohno's men (Ohno's body was never found), Kōfuku Yamakage and Rikio Matsudo, lasted three and a half years, surrendering on January 6, 1949.


title: Iwo Jima

text: On February 19, 1985, the 40th anniversary of the day that U.S. forces began the assault on the island, veterans from both forces gathered for the Reunion of Honor just a few meters/yards away from the spot where U.S. Marines had landed on the island.


title: Iwo Jima

text: On the 40th anniversary of the battle of Iwo Jima, American and Japanese veterans met again on these same sands, this time in peace and friendship. We commemorate our comrades, living and dead, who fought here with bravery and honor, and we pray together that our sacrifices on Iwo Jima will always be remembered and never be repeated.


title: Iwo Jima

text: It is inscribed on both sides of the plaque, with the English translation facing the beaches where U.S. forces landed and the Japanese translation facing inland, where Japanese troops defended their position.


title: Iwo Jima

text: After that, the Japan–U.S. combination memorial service of the 50th anniversary was held in front of this monument in March 1995. The 55th anniversary was held in 2000, followed by a 60th reunion in March 2005 (see U.S. National Park Service photo below), and a 70th anniversary ceremony on March 21, 2015.


title: Iwo Jima

text: A memorial service held on the island in 2007 got particular attention because it coincided with the release of the movie "Letters from Iwo Jima." The joint U.S.–Japanese ceremony was attended by Yoshitaka Shindo, a Japanese lawmaker who is the grandson of the Japanese commander during the battle, Lt. Gen. Tadamichi Kuribayashi, and Yasunori Nishi, the son of Colonel Baron Takeichi Nishi, the Olympic gold medalist equestrian who died commanding a tank unit on the island.


title: Iwo Jima

text: The Japan Maritime Self-Defense Force (JMSDF) operates a naval air base on the island at Central Field. The airstrip is 2,650 meters (8,700 ft) long and 60 meters (200 ft) wide. The JMSDF is in charge of support, air traffic control, fueling, and rescue. The airstrip is occasionally used for emergency landings by commercial airplanes flying transpacific routes. The IATA airport code of IWO and the ICAO airport code of RJAW are assigned to the airfield. The Japan Air Self-Defense Force also uses the base. The Japan Ground Self-Defense Force is in charge of explosive ordnance disposal, and maintains a garrison of 400 troops on the island. Two abandoned airfields from World War II are nearby, North Field to the north of the current air base, and an unfinished Japanese airfield to the south of the base, which was improved after the U.S. invasion of the island.


title: Iwo Jima

text: The U.S. Navy's Carrier Air Wing Five, based at the United States Naval Air Facility Atsugi when not deployed aboard , also uses the base for field carrier landing practice (FCLP). The U.S. Navy still has a disused communication facility (Iwo-Jima Communication Site) on the island, while the U.S. Coast Guard's Iwo Jima LORAN-C transmitter facility was transferred to Japan in 1993 and demolished in 1994.


title: Iwo Jima

text: Civilian access to the island is restricted to those attending memorial services for U.S. and Japanese fallen soldiers, construction workers for the naval air base, and meteorological agency officials. The Japanese troops stationed on the island register their residential addresses in Ayase, Kanagawa or Sayama, Saitama for voting, tax, and social security purposes. Officially, there is no population on the island.


title: Iwo Jima

text: Iwo Jima is claimed to be one of a number of Japanese islands which has been used by the United States to host nuclear arms, according to Robert S. Norris, William M. Arkin, and William Burr writing for the "Bulletin of the Atomic Scientists" in early 2000.


title: Iwo Jima

text: This is despite a Japanese policy of not allowing nuclear weapons on Japanese soil. Whether the site is used for this purpose is unknown, as great secrecy surrounds the United States' siting of nuclear arms bases; but on December 12, 1999, U.S. Under Secretary for Defense Policy Walter Slocombe told "The New York Times", "Our position is that there have been no violations of our obligations under the security treaty and related arrangements."


title: Iwo Jima

text: There were nuclear weapons on Chichi Jima and Iwo Jima (Iwo To), an enormous and varied nuclear arsenal on Okinawa, nuclear bombs (without their fission cores) stored on the mainland at Misawa and Itazuke airbases (and possibly at Atsugi, Iwakuni, Johnson, and Komaki airbases as well), and nuclear-armed U.S. Navy ships stationed in Sasebo and Yokosuka. "..." Chichi Jima, Iwo Jima, and Okinawa were under U.S. occupation, that the bombs stored on the mainland lacked their plutonium and/ or uranium cores, and that the nuclear-armed ships were a legal inch away from Japanese soil. All in all, this elaborate stratagem maintained the technicality that the United States had no nuclear weapons "in Japan."


title: Labyrinth

text: In Greek mythology, the Labyrinth (, ) was an elaborate, confusing structure designed and built by the legendary artificer Daedalus for King Minos of Crete at Knossos. Its function was to hold the Minotaur, the monster eventually killed by the hero Theseus. Daedalus had so cunningly made the Labyrinth that he could barely escape it after he built it.


title: Labyrinth

text: Although early Cretan coins occasionally exhibit branching (multicursal) patterns, the single-path (unicursal) seven-course "Classical" design without branching or dead ends became associated with the Labyrinth on coins as early as 430 BC, and similar non-branching patterns became widely used as visual representations of the Labyrinth – even though both logic and literary descriptions make it clear that the Minotaur was trapped in a complex branching maze. Even as the designs became more elaborate, visual depictions of the mythological Labyrinth from Roman times until the Renaissance are almost invariably unicursal. Branching mazes were reintroduced only when hedge mazes became popular during the Renaissance.


title: Labyrinth

text: In English, the term "labyrinth" is generally synonymous with "maze". As a result of the long history of unicursal representation of the mythological Labyrinth, however, many contemporary scholars and enthusiasts observe a distinction between the two. In this specialized usage "maze" refers to a complex branching multicursal puzzle with choices of path and direction, while a unicursal "labyrinth" has only a single path to the center. A labyrinth in this sense has an unambiguous route to the center and back and presents no navigational challenge.


title: Labyrinth

text: Unicursal labyrinths appeared as designs on pottery or basketry, as body art, and in etchings on walls of caves or churches. The Romans created many primarily decorative unicursal designs on walls and floors in tile or mosaic. Many labyrinths set in floors or on the ground are large enough that the path can be walked. Unicursal patterns have been used historically both in group ritual and for private meditation, and are increasingly found for therapeutic use in hospitals and hospices.


title: Labyrinth

text: "Labyrinth" is a word of pre-Greek origin whose derivation and meaning are uncertain. Maximillian Mayer suggested as early as 1892 that "labyrinthos" might derive from "labrys", a Lydian word for "double-bladed axe". Arthur Evans, who excavated the palace of Knossos in Crete early in the 20th century, suggested that the palace was the original labyrinth, and since the double axe motif appears in the palace ruins, he asserted that "labyrinth" could be understood to mean "the house of the double axe". The same symbol, however, was discovered in other palaces in Crete. Nilsson observed that in Crete the double axe is not a weapon and always accompanies goddesses or women and not a male god.


title: Labyrinth

text: The association with "labrys" lost some traction when Linear B was deciphered in the 1950s, and an apparent Mycenaean Greek rendering of "labyrinth" appeared as (). This may be related to the Minoan word "du-bu-re" or "du-pu-re", which appears in Linear A on libation tablets and in connection with Mts Dikte and Ida, both of which are associated with caverns. Caverns near Gortyna, the Cretan capital in the 1st century AD, were called "labyrinthos".


title: Labyrinth

text: Pliny's "Natural History" gives four examples of ancient labyrinths: the Cretan labyrinth, an Egyptian labyrinth, a Lemnian labyrinth, and an Italian labyrinth. These are all complex underground structures, and this appears to have been the standard Classical understanding of the word.


title: Labyrinth

text: Beekes also finds the relation with "labrys" speculative, and suggests instead a relation with Greek ('narrow street').


title: Labyrinth

text: When the Bronze Age site at Knossos was excavated by explorer Arthur Evans, the complexity of the architecture prompted him to suggest that the palace had been the Labyrinth of Daedalus. Evans found various bull motifs, including an image of a man leaping over the horns of a bull, as well as depictions of a labrys carved into the walls. On the strength of a passage in the "Iliad", it has been suggested that the palace was the site of a dancing-ground made for Ariadne by the craftsman Daedalus,


title: Labyrinth

text: where young men and women, of the age of those sent to Crete as prey for the Minotaur, would dance together. By extension, in popular legend the palace is associated with the myth of the Minotaur.


title: Labyrinth

text: In the 2000s, archaeologists explored other potential sites of the labyrinth. Oxford University geographer Nicholas Howarth believes that "Evans's hypothesis that the palace of Knossos is also the Labyrinth must be treated sceptically." Howarth and his team conducted a search of an underground complex known as the Skotino cave but concluded that it was formed naturally. Another contender is a series of tunnels at Gortyn, accessed by a narrow crack but expanding into interlinking caverns. Unlike the Skotino cave, these caverns have smooth walls and columns, and appear to have been at least partially man-made. This site corresponds to a labyrinth symbol on a 16th-century map of Crete in a book of maps in the library of Christ Church, Oxford. A map of the caves themselves was produced by the French in 1821. The site was also used by German soldiers to store ammunition during the Second World War. Howarth's investigation was shown on a documentary produced for the National Geographic Channel.


title: Labyrinth

text: More generally, "labyrinth" might be applied to any extremely complicated maze-like structure. In Book II of his "Histories", Herodotus applies the term "labyrinth" to a building complex in Egypt "near the place called the City of Crocodiles", that he considered to surpass the pyramids:


title: Labyrinth

text: During the nineteenth century, the remains of this ancient Egyptian structure were discovered at Hawara in the Faiyum Oasis by Flinders Petrie at the foot of the pyramid of the twelfth-dynasty pharaoh Amenemhat III (reigned c. 1860 BC to c. 1814 BC). The Classical accounts of various authors (Herodotus, Strabo, Pliny the Elder, among others) are not entirely consistent, perhaps due to degradation of the structure during Classical times. The structure may have been a collection of funerary temples such as are commonly found near Egyptian pyramids. Records indicate that Amenemhat's daughter Sobekneferu made additions to the complex during her reign as king of Egypt.


title: Labyrinth

text: In 1898, the "Harpers Dictionary of Classical Antiquities" described the structure as "the largest of all the temples of Egypt, the so-called Labyrinth, of which, however, only the foundation stones have been preserved."


title: Labyrinth

text: Herodotus' description of the Egyptian Labyrinth inspired some central scenes in Bolesław Prus' 1895 historical novel "Pharaoh".


title: Labyrinth

text: Pliny the Elder's "Natural History" (36.90) lists the legendary Smilis, reputed to be a contemporary of Daedalus, together with the historical mid-sixth-century BC architects and sculptors Rhoikos and Theodoros as two of the makers of the Lemnian labyrinth, which Andrew Stewart regards as "evidently a misunderstanding of the Samian temple's location "en limnais" ['in the marsh']."


title: Labyrinth

text: According to Pliny, the tomb of the great Etruscan general Lars Porsena contained an underground maze. Pliny's description of the exposed portion of the tomb is intractable; Pliny, it seems clear, had not observed this structure himself, but is quoting the historian and Roman antiquarian Varro.


title: Labyrinth

text: A design essentially identical to the 7-course "classical" pattern appeared in Native American culture, the Tohono O'odham people labyrinth which features I'itoi, the "Man in the Maze." The Tonoho O'odham pattern has two distinct differences from the classical: it is radial in design, and the entrance is at the top, where traditional labyrinths have the entrance at the bottom (see below). The earliest appearances cannot be dated securely; the oldest is commonly dated to the 17th century.


title: Labyrinth

text: Unsubstantiated claims have been made for the early appearance of labyrinth figures in India, such as a prehistoric petroglyph on a riverbank in Goa purportedly dating to circa 2500 BC. Other examples have been found among cave art in northern India and on a dolmen shrine in the Nilgiri Mountains, but are difficult to date accurately. Securely datable examples begin to appear only around 250 BC. Early labyrinths in India typically follow the Classical pattern or a local variant of it; some have been described as plans of forts or cities.


title: Labyrinth

text: Labyrinths appear in Indian manuscripts and Tantric texts from the 17th century onward. They are often called "Chakravyuha" in reference to an impregnable battle formation described in the ancient Mahabharata epic. Lanka, the capital city of mythic Rāvana, is described as a labyrinth in the 1910 translation of Al-Beruni's "India" (c. 1030 AD) p. 306 (with a diagram on the following page).


title: Labyrinth

text: By the White Sea, notably on the Solovetsky Islands, there have been preserved more than 30 stone labyrinths. The most remarkable monument is the Stone labyrinths of Bolshoi Zayatsky Island – a group of some 13 stone labyrinths on 0.4 km area of one small island. Local archaeologists have speculated that these labyrinths may be 2,000–3,000 years old, though most researchers remain dubious.


title: Labyrinth

text: The 7-course "Classical" or "Cretan" pattern known from Cretan coins (ca 400–200 BC) appears in several examples from antiquity, some perhaps as early as the late Stone Age or early Bronze Age. Roman floor mosaics typically unite four copies of the classical labyrinth (or a similar pattern) interlinked around the center, squared off as the medium requires, but still recognisable. An image of the Minotaur or an allusion to the legend of the Minotaur appears at the center of many of these mosaic labyrinths.


title: Labyrinth

text: The four-axis medieval patterns may have developed from the Roman model, but are more varied in how the four quadrants of the design are traced out. The Minotaur or other danger is retained in the center of several medieval examples. The Chartres pattern (named for its appearance in Chartres Cathedral) is the most common medieval design; it appears in manuscripts as early as the 9th century.


title: Labyrinth

text: When the early humanist Benzo d'Alessandria visited Verona before 1310, he noted the ""Laberinthum" which is now called the Arena"; perhaps he was seeing the "cubiculi" beneath the arena's missing floor.


title: Labyrinth

text: The full flowering of the medieval labyrinth came about from the twelfth through fourteenth centuries with the grand pavement labyrinths of the gothic cathedrals, notably Chartres, Reims and Amiens in northern France. The symbolism or purpose behind these is unclear, and may have varied from one installation to the next. Descriptions survive of French clerics performing a ritual Easter dance along the path on Easter Sunday. Some labyrinths may have originated as allusions to the Holy City; and some modern writers have theorized that prayers and devotions may have accompanied the perambulation of their intricate paths. Although some books (in particular guidebooks) suggest that the mazes on cathedral floors served as substitutes for pilgrimage paths, the earliest attested use of the phrase "chemin de Jerusalem" (path to Jerusalem) dates to the late 18th century when it was used to describe mazes at Reims and Saint-Omer. The accompanying ritual, depicted in Romantic illustrations as involving pilgrims following the maze on their knees while praying, may have been practiced at Chartres during the 17th century. The cathedral labyrinths are thought to be the inspiration for the many turf mazes in the UK, such as survive at Wing, Hilton, Alkborough, and Saffron Walden.


title: Labyrinth

text: Over the same general period, some 500 or more non-ecclesiastical labyrinths were constructed in Scandinavia. These labyrinths, generally in coastal areas, are marked out with stones, most often in the simple 7- or 11-course classical forms. They often have names which translate as "Troy Town." They are thought to have been constructed by fishing communities: trapping malevolent trolls or winds in the labyrinth's coils might ensure a safe fishing expedition. There are also stone labyrinths on the Isles of Scilly, although none is known to date from before the nineteenth century.


title: Labyrinth

text: There are examples of labyrinths in many disparate cultures. The symbol has appeared in various forms and media (petroglyphs, classic-form, medieval-form, pavement, turf, and basketry) at some time throughout most parts of the world, from Native North and South America to Australia, Java, India, and Nepal.


title: Labyrinth

text: In recent years, there has been a resurgence of interest in labyrinths and a revival in labyrinth building, of both unicursal and multicursal patterns. Approximately 6,000 labyrinths have been registered with the Worldwide Labyrinth Locator; these are located around the world in private properties, libraries, schools, gardens, recreational areas, as well as famous temples and cathedrals.


title: Labyrinth

text: The labyrinth is also treated in contemporary fine arts. Examples include Piet Mondrian's "Pier and Ocean" (1915), Joan Miró's "Labyrinth" (1923), Pablo Picasso's "Minotauromachy" (1935), M. C. Escher's "Relativity" (1953), Friedensreich Hundertwasser's "Labyrinth" (1957), Jean Dubuffet's "Logological Cabinet" (1970), Richard Long's "Connemara sculpture" (1971), Joe Tilson's "Earth Maze" (1975), Richard Fleischner's "Chain Link Maze" (1978), István Orosz's "Atlantis Anamorphosis" (2000), Dmitry Rakov's "Labyrinth" (2003), and drawings by contemporary American artist Mo Morales employing what the artist calls "Labyrinthine projection." The Italian painter Davide Tonato has dedicated many of his artistic works to the labyrinth theme. In modern imagery, the labyrinth of Daedalus is often represented by a multicursal maze, in which one may become lost.


title: Labyrinth

text: Mark Wallinger has created a set of 270 enamel plaques of unicursal labyrinth designs, one for every tube station in the London Underground, to mark the 150th anniversary of the Underground. The plaques were installed over a 16-month period in 2013 and 2014, and each is numbered according to its position in the route taken by the contestants in the 2009 Guinness World Record Tube Challenge.


title: Labyrinth

text: Prehistoric labyrinths may have served as traps for malevolent spirits or as paths for ritual dances. Many Roman and Christian labyrinths appear at the entrances of buildings, suggesting that they may have served a similar apotropaic purpose. In their cross-cultural study of signs and symbols, "Patterns that Connect", Carl Schuster and Edmund Carpenter present various forms of the labyrinth and suggest various possible meanings, including not only a sacred path to the home of a sacred ancestor, but also, perhaps, a representation of the ancestor him/herself: ."..many [New World] Indians who make the labyrinth regard it as a sacred symbol, a beneficial ancestor, a deity. In this they may be preserving its original meaning: the ultimate ancestor, here evoked by two continuous lines joining its twelve primary joints." Schuster also observes the common theme of the labyrinth being a refuge for a trickster; in India, the demon Ravana has dominion over labyrinths, the trickster Djonaha lives in a labyrinth according to Sumatran Bataks, and Europeans say it is the home of a rogue.


title: Labyrinth

text: One can think of labyrinths as symbolic of pilgrimage; people can walk the path, ascending toward salvation or enlightenment. Author Ben Radford conducted an investigation into some of the claims of spiritual and healing effects of labyrinths, reporting on his findings in his book Mysterious New Mexico.


title: Labyrinth

text: Many labyrinths have been constructed recently in churches, hospitals, and parks. These are often used for contemplation; walking among the turnings, one loses track of direction and of the outside world, and thus quiets the mind.


title: Labyrinth

text: Labyrinths have on various occasions been used in Christian tradition as a part of worship. The earliest known example is from a fourth-century pavement at the Basilica of St Reparatus, at Orleansville, Algeria, with the words "Sancta Eclesia" at the center, though it is unclear how it might have been used in worship.


title: Labyrinth

text: In medieval times, labyrinths began to appear on church walls and floors around 1000 AD. The most famous medieval labyrinth, with great influence on later practice, was created in Chartres Cathedral.


title: Labyrinth

text: The use of labyrinths has recently been revived in some contexts of Christian worship. Many churches in Europe and North America have constructed permanent, typically unicursal, labyrinths, or employ temporary ones (e.g., painted on canvas or outlined with candles). For example, a labyrinth was set up on the floor of St Paul's Cathedral for a week in March 2000. Some conservative Christians disapprove of labyrinths, considering them pagan practices or "new age" fads.


title: Labyrinth

text: Labyrinths and mazes have been embraced by the video game industry, and countless video games include such a feature.


title: Labyrinth

text: A number of film, game, and music creations feature labyrinths. For instance, the avant-garde multi-screen film "In the Labyrinth" presents a search for meaning in a symbolic modern labyrinth. The well-received 2006 film Pan's Labyrinth draws heavily upon labyrinth legend for symbolism. A magical labyrinth appears in the third episode "And The Horns of a Dilemma" of "The Librarians". Please see Labyrinth (disambiguation) for a further list of titles.


title: Labyrinth

text: The Argentine writer Jorge Luis Borges was entranced with the idea of the labyrinth, and used it extensively in his short stories (such as "The House of Asterion" in "The Aleph"). His use of it has inspired other authors (e.g. Umberto Eco's "The Name of the Rose", Mark Z. Danielewski's "House of Leaves"). Additionally, Roger Zelazny's fantasy series "The Chronicles of Amber" features a labyrinth, called "the Pattern," which grants those who walk it the power to move between parallel worlds. In Rick Riordan's series Percy Jackson & the Olympians, the events of the fourth novel "The Battle of the Labyrinth" predominantly take place within the labyrinth of Daedalus, which has followed the heart of the West to settle beneath the United States. Australian author Sara Douglass incorporated some labyrinthine ideas in her series The Troy Game, in which the Labyrinth on Crete is one of several in the ancient world, created with the cities as a source of magical power. Lawrence Durrell's "The Dark Labyrinth" depicts travelers trapped underground in Crete. Because a labyrinth can serve as a metaphor for situations that are difficult to be extricated from, Octavio Paz titled his book on Mexican identity "The Labyrinth of Solitude", describing the Mexican condition as orphaned and lost.


title: Pretty Boy Floyd

text: Charles Arthur Floyd (February 3, 1904 – October 22, 1934), nicknamed Pretty Boy Floyd, was an American bank robber. He operated in the West and Central states, and his criminal exploits gained widespread press coverage in the 1930s. He was seen positively by the public because it was believed that during robberies he burned mortgage documents, freeing many people from their debts. He was pursued and killed by a group of Bureau of Investigation (BOI) agents led by Melvin Purvis. Historians have speculated as to which officers were at the event, but accounts document that local officers Robert "Pete" Pyle and George Curran were present at his fatal shooting and also at his embalming. Floyd has continued to be a familiar figure in American popular culture, sometimes seen as notorious, other times portrayed as a tragic figure, even a victim of the hard times of the Great Depression in the United States.


title: Pretty Boy Floyd

text: Floyd was born in Bartow County, Georgia in 1904. His family moved to Akins, Oklahoma in 1911, and he grew up there. He was arrested at age 18 after he stole $350 from a local post office. Three years later, he was arrested for a payroll robbery on September 16, 1925 in St. Louis, Missouri and was sentenced to five years in prison. He served three and a half years before being granted parole.


title: Pretty Boy Floyd

text: Floyd entered into partnerships with criminals in the Kansas City underworld after his parole. He committed a series of bank robberies over the next several years, and it was during this period that he acquired the nickname "Pretty Boy," although accounts differ. In one account Orville Drake gave him the name because he would wear a white button-up dress shirt and slacks to work in the oil fields. The men on the rig began calling him "Pretty Boy" which was later turned into "Pretty Boy Floyd". In another account, the payroll master in the 1925 St. Louis Kroger office holdup described one of the robbers as "a pretty boy with apple cheeks". Floyd despised the nickname.


title: Pretty Boy Floyd

text: In 1929, Floyd was wanted in numerous cases. On March 9, he was arrested in Kansas City on investigation, and again on May 7 for vagrancy and suspicion of highway robbery, but he was released the next day. Two days later, he was arrested in Pueblo, Colorado and charged with vagrancy. He was fined $50.00 and sentenced to 60 days in jail.


title: Pretty Boy Floyd

text: Floyd was arrested in Akron, Ohio on March 8, 1930 under the alias Frank Mitchell and charged with the murder of an Akron police officer who had been killed during a robbery that evening. He was arrested in Toledo, Ohio on suspicion on May 20. He was convicted of a Sylvania Ohio Bank Robbery and sentenced on November 24, 1930 to 12 to 15 years in Ohio State penitentiary, but he escaped.


title: Pretty Boy Floyd

text: Floyd was a suspect in the deaths of Kansas City brothers Wally and Boll Ash who were rum-runners, found dead in a burning car on March 25, 1931. Members of his gang killed Patrolman R. H. Castner of Bowling Green, Ohio on April 23. On July 22, Floyd killed federal agent Curtis C. Burke in Kansas City, Missouri.


title: Pretty Boy Floyd

text: Former sheriff Erv Kelley of McIntosh County, Oklahoma was shot by Floyd while trying to arrest him on April 7, 1932. In November, three members of Floyd's gang attempted to rob the Farmers and Merchants Bank in Boley, Oklahoma. Despite his life of crime, Floyd was viewed positively by the general public. When he robbed banks, he allegedly destroyed mortgage documents, but this has never been confirmed and may be myth. He was often protected by locals of Oklahoma who referred to him as "Robin Hood of the Cookson Hills".


title: Pretty Boy Floyd

text: Floyd and Adam Richetti became the primary suspects in a gunfight known as the "Kansas City massacre" on June 17, 1933 which resulted in the deaths of four law enforcement officers. J. Edgar Hoover leveraged the incident to seek more authority to pursue Floyd, although historians are divided as to whether Floyd was involved. The gunfight was an attack by Vernon Miller and accomplices on lawmen escorting robber Frank "Jelly" Nash to a car parked at the Union Station in Kansas City, Missouri. Kansas City detectives William Grooms and Frank Hermanson, Oklahoma police chief Otto Reed, and special agent Ray Caffrey were killed. Nash was also killed while sitting in the car, shot in the head by his would-be rescuers. Two other Kansas City police officers survived by slumping forward in the back seat and feigning death. As the gunmen inspected the car, another officer responded from the station and fired at them, forcing them to flee. Miller was found dead on November 27, 1933 outside Detroit, Michigan, having been beaten and strangled.


title: Pretty Boy Floyd

text: Floyd and Richetti were allegedly Miller's accomplices. Factors weighing against them included their apparent presence in Kansas City at the time, eyewitness identifications (which have been contested), Richetti's fingerprint recovered from a beer bottle at Miller's hideout, an underworld account naming Floyd and Richetti as the gunmen, and Hoover's firm advocacy of their guilt. Fellow bank robber Alvin Karpis claimed that Floyd confessed involvement. On the other side of the issue, the bandit alleged to have been Floyd was supposed to have been wounded by a gunshot to the shoulder in the attack, and Floyd's body showed no sign of this injury when examined later. The underworld account identifying Floyd and Richetti as the killers was offset by equally unreliable underworld accounts proclaiming their innocence. The Floyd family has maintained that Floyd admitted to many other crimes but vehemently denied involvement in this one, as did Richetti.


title: Pretty Boy Floyd

text: Kansas City police received a postcard dated June 30, 1933 from Springfield, Missouri which read: "Dear Sirs - I - Charles Floyd - want it made known that I did not participate in the massacre of officers at Kansas City. Charles Floyd". The police department believed the note to be genuine. Floyd also reportedly denied involvement in the massacre to the agents who had fatally wounded him. In addition, a 2002 book on the massacre attributes at least some of the killing to friendly fire by a lawman who was unfamiliar with his weapon, based on ballistic tests.


title: Pretty Boy Floyd

text: The BOI named Floyd "Public Enemy No. 1" on July 23, 1934, following the death of John Dillinger. Local police and BOI agents led by Melvin Purvis shot Floyd on October 22, 1934 in a corn field in East Liverpool, Ohio. Accounts differ on who shot him and the manner in which he was killed.


title: Pretty Boy Floyd

text: Floyd and Richetti had left Buffalo, New York on October 18, and their vehicle slid into a telephone pole in heavy fog. No one was injured, but the car was disabled, so they sent two female companions to get a tow truck. They planned to have the women accompany the tow truck driver into town and have the vehicle repaired while they waited by the roadside.


title: Pretty Boy Floyd

text: After dawn on October 19, motorist Joe Fryman and his son-in-law David O'Hanlon passed by, observing two men dressed in suits lying by the roadside. They thought it suspicious and informed Wellsville, Ohio police chief John H. Fultz. Fultz investigated with officers Grover Potts and William Erwin. Richetti saw the lawmen and fled into the woods, pursued by two officers, while Fultz went towards Floyd. Floyd immediately drew his gun and fired, and he and Fultz engaged one another in a gunfight, during which Fultz was wounded in the foot and Potts was wounded in the right shoulder, before Floyd fled into the forest. After enlisting the help of another local police officer, Chester C. Smith (February 14, 1895 – October 23, 1984), who had served as a sniper during World War I, the group of lawmen resumed the pursuit and successfully apprehended Richetti, Floyd however remained on the run. News of the search quickly spread, local police in the surrounding areas were mobilized and a team of BOI agents was quickly dispatched.