l proceedings. They believe there are more sensible ways to handle law enforcement abuses. Liberals, on the other hand, generally have defended the exclusionary rule, both as an appropriate judicial remedy for Fourth Amendment violations and because it can operate to deter police misconduct. A closer examination of the issue will show that the rule is fundamentally sound, although for somewhat different reasons than liberal legal scholars typically offer.
             The case Katz v. United States (1967) dealt with the applicability of the exclusionary rule to the States. It resulted in a 7-1 vote. Katz was arrested for illegal gambling after using a public phone to transmit "gambling information." The FBI had attached an electronic listening/recording device onto the outside of the public phone booth that Katz habitually used. They argued that this constituted a legal action since they never actually entered the phone booth. The Court, however, ruled in favor of Katz, stating the Fourth Amendment allowed for the protection of a person and not just a person's property against illegal searches. Whatever a citizen "seeks to preserve as private, even in an area accessible to the public, may be constitutionally protected." "...[T] he Government's activities in electronically listening to and recording the petitioner's words violated the privacy upon which he justifiably relied while using the telephone booth and thus constituted a "search and seizure" within the meaning of the Fourth Amendment."
             The case California v. Greenwood, (1988) was based on information indicating that respondent Greenwood might be engaged in narcotics trafficking, police twice obtained from his regular trash collector garbage bags left on the curb in front of his house. On the basis of items in the bags, which were indicative of narcotics use, the police obtained warrant searching the house, discovered controlled substances during the searches, and arrested responden...