Cambridge University Press). Any added probable cause after the fact would be inadmissible in a court of law.). Perhaps the best way to understand reasonable suspicion is through a real-world example: A police officer witnesses a man stagger to his car and enter the vehicle. Probable cause is established when a police officer determines he or she has enough information to believe there is a probable chance of criminal activity. Crossing onto shoulder of roadway multiple times + unusual use of turn signal + late at night + close to bars = reasonable suspicion (DWI). Jose Sanchez, a correctional officer at the Olympic Corrections Center, was stopped in his vehicle by Border Patrol agents, who said the tint on his windows was too dark. Because most DUI arrestsand many other arrests that result in criminal chargesare made without warrants, its critical that both law enforcement officers and citizens understand the basic elements of reasonable suspicion and probable cause. However, he does have reasonable suspicion that the driver of the vehicle is driving under the influence and can, therefore, make the traffic stop. The driver is taken into custody and arrested for driving under the influence. The reasonable suspicion inquiry "falls considerably short" of 51% accuracy, see . Testing is more commonly done on employees in safe-sensitive jobs, at which accidents could cause serious harm or injury. Quickly pulling out of a bar parking lot = not reasonable suspicion (DWI). Instead, constitutional law developed under the Supreme Court's Terry standard demands that the officer is able to articulate factual observations justifying the officer's stop. Although the officer had no probable cause to search Stevens car, or to engage in a very thorough search of his person initially, he did have the right to search for weapons. In one example, an employee was accused of theft and was terminated based on reasonable suspicion. If he arrests you, then he needs to have probable cause to do so (see Probable Cause. The term reasonable suspicion refers to a standard by which police officers are judged to have authority to briefly detain a person. Here are some examples of items that might be on a reasonable suspicion checklist: Unsteadiness or inability to walk Slurred, incoherent, or slobbering speech Being argumentative or unusually sarcastic Being hyperactive Using out-of-character profanity A flushed, pale, or sweaty face Poor hygiene Odor on their breath The word in the example sentence does not match the entry word. One moose, two moose. When an officer stops someone to search the person, courts require that the officer has either a search warrant, probable cause to search, or a reasonable suspicion to search. The facts here are limited, and the officer doesn't quite have probable cause to make a traffic stop. Reasonable suspicion isa standard used in criminal procedure. all reasonable inferences. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Steven was driving away from a neighborhood known for its drug activity, when police stop him. Probable cause and reasonable suspicion are two legal terms often used by law enforcement and in police work. Reasonable suspicion is a legal standard of proof in United States law that is less than probable cause, the legal standard for arrests and warrants, but more than an "inchoate and unparticularized suspicion or 'hunch ' "; it must be based on "specific and articulable facts", "taken together with rational inferences from those facts", and the suspicion must be associated with the specific . In the Terry case, the court was looking at whether the police could pat down the suspect for weapons even though probable cause didn't exist. (Note: Probable cause cannot be after the fact. Process and policy are both critical when it comes to drug . When police do stop someone with reasonable suspicion, they are allowed to frisk him, or do a pat-down search of his clothing, for weapons. The Fourth Amendment requires that before stopping the suspect, the police must have a reasonable suspicion that a crime has been, is being, or is about to be committed by the suspect. Both reasonable suspicion and probable cause have to do with determining when police officers can stop or detain a person, search for evidence, and arrest a person. In this example of reasonable suspicion not being adhered to, the U.S. Border Patrol settled with Sanchez and the other plaintiffs to the lawsuit in 2013. Amphetamines (including amphetamine & methamphetamine), Opiates (including morphine, codeine & heroin), Odor of alcohol on the employees body or breath, Inability or difficulty completing routine tasks. All rights reserved. The Fourth Amendment guarantees everyone the right to proceed without unreasonable search of their person, houses, papers and effects. To unlock this lesson you must be a Study.com Member. Ann's daughter is recovered safely. We and our partners use cookies to Store and/or access information on a device. Explore the legal standard of reasonable suspicion and what authority that gives the officer over a citizen. Following, the Denver criminal defense attorneys at Wolf Law discuss when and how reasonable suspicion and probable cause may be applied. Section 1. Criminal evidence found during an unreasonable search (i.e. Once established, it allows a law enforcement officer to hold someone briefly and pat them down. Star Athletica, L.L.C. The court also held that the knowledge is not absolute, but rather steeped in probabilities. The fascinating story behind many people's favori Can you handle the (barometric) pressure? Reasonable suspicion means that any reasonable person would suspect that a crime was in the process of being committed, had been committed or was going to be committed very soon. InBrown, the Court held that evidence "obtained by the exploitation of an illegal arrest" is not admissible. Accessed 2 Mar. I would definitely recommend Study.com to my colleagues. Example of Reasonable Suspicion Stop Max is pulled over by a police officer who saw his car weaving on the roadway. In recent years, there has been some controversy over some jurisdictions policies to stop and frisk people for no clear reason. - Reasonable Suspicion is the authority which gives an Officer of someone of said power to investigate the activity and who may be involved. reasonable suspicion noun : an objectively justifiable suspicion that is based on specific facts or circumstances and that justifies stopping and sometimes searching (as by frisking) a person thought to be involved in criminal activity at the time see also reasonable cause at cause sense 2 compare probable cause at cause sense 2, terry stop New Jersey has set the precedent that probable cause is not necessary to search a student on school grounds; reasonable suspicion is enough to search a student's belongings. If the officer has reasonable suspicion the detainee is armed, the officer may perform a "pat-down" of the person's outer garments for weapons. 34956. and S.G. Portwood, Reasonable suspicion of child abuse: finding a common language. You should tell him you want your attorney present for any further questions (5th Amendment and 6th Amendment).. In Illinois v. Caballes, the Supreme Court held that a drug dog may sniff the exterior of a vehicle during a traffic stop so long as any delay in calling the dog to the scene does not unreasonably prolong the traffic stop. Upon interacting with the driver, the officer smells alcohol on the mans breath, sees that the mans eyes are bloodshot, and notices that the mans speech is slurred and his responses to questions are unintelligible. She gives police a detailed description of the carjacker and tells the color, make, and model of her car. All other trademarks and copyrights are the property of their respective owners. Or. The baggie contains two rocks of crack cocaine, so the officer arrests Sketchy Joe. In order to legally search for drugs or other items, law enforcement officers must have probable cause. If the officer holds you too long or investigates matters not related to the initial stop, then he has violated your constitutional right not to be unreasonably seized (4th Amendment). Post-accident. If the officer says, yes ask if you will be free to leave once the ticket is written?, This is the typical scenario, and you can consider yourself detained. Visiting this website or contacting our law firm does not make Wolf Law LLC your legal counsel. In descending order of what gives an officer the broadest authority to perform a search, courts have found that the order is search warrant, probable cause, and then reasonable suspicion. evidence that the dog sniff would have detected inRodriguezafter the police officer had already completed his search) is subject to the exclusionary rule and will be excluded from being introduced at trial. Such a detention does not violate the Fourth Amendment prohibition on unreasonable searches and seizure, though it must be brief. [3] If police additionally have reasonable suspicion that a person so detained is armed and dangerous, they may "frisk" the person for weapons, but not for contraband like drugs. He provides police with her address which is at a residence owned by her new boyfriend. But reasonable suspicion does not mean a guess or hunch. In Hiibel v. Sixth Judicial District Court of Nevada the Court further established that a state may require, by law, that a person verbally identify himself or herself to an officer during a stop;[5] some states (e.g., Colorado[6]) require that a person detained provide additional information. Levi, B.H. University of Minnesota Law Review article, University of Pennsylvania Law Review article. When an officer stops someone to search the person, courts require that the officer has either a search warrant, probable cause to search, or a reasonable suspicion to search. However, reasonable suspicion does not apply merely because a person refuses to answer questions, declines to allow a voluntary search, or is of a particular race or ethnicity.[22]. If he allows it, call your attorney! There are no vehicles in the driveway and everything appears normal. Sanchez had previously been stopped, while driving with a family member, and interrogated by the Border Patrol about his immigration status. For non-regulated testing, an employer has the ability to create their own definition of a reasonable suspicion test. Use of police overhead lights + boxing-in your car = detention (i.e. We invite you to contact our Denver criminal defense attorneys for a consultation regarding your individual circumstances. To protect themselves, many employers require specific documentation of incidents that lead supervisors to suspect that an employee is under the influence. The distinction between the two is clear (now). This is the reason for the reasonable suspicion standard, which allows officers to stop or detain people temporarily. Taking Steven into custody for the warrant, the officer searches Stevens clothing for weapons, and discovers several small baggies of white pills stuffed in the lining of his jackets pocket. Americans are protected against unreasonable searches and seizures by the Fourth Amendment to the U.S. Constitution. If it exists, then the officer can detain, search for weapons, and question the person. Reasonable suspicion is used in determining the legality of a police officer's decision to perform a search. Flaherty, E.G. Examples of reasonable suspicion . Any evidence obtained isinadmissible in a later court proceeding. Examples of insufficient reasonable suspicion: Evidence of flight alone (i.e. The Fourth Amendment of the United States Constitution explicitly requires that law enforcement officers establish probable cause and are refrained from conducting illegal arrests, searches, and seizures of property. Note: Reasonable suspicion is used in determining the legality of a police officer's decision to perform a search. Probable cause exists if an officer has cause to believe that a crime has occurred or is about to occur, and/or if the person posses evidence of a crime. The terms of the settlement agreement required the Border Patrol to acknowledge that its agents must have reasonable suspicion that a person is violating the law, in order to legally stop or detain him or her. 2. The Court held that that sniff search violated the Fourth Amendment as it was prolonged beyond the time reasonably required to complete the stop. Weaving to avoid debris on road = not reasonable suspicion (DWI). The inclusion of client reviews on this site does guarantee that your case, or any case, will have a similar result. A law enforcement officer is patrolling a neighborhood that has seen several in-home invasions recently. Denver Criminal Defense Lawyer Kelley Special Guest for NARSOL in Action, Understanding Colorados Sex Offender Registry, Flaws in Our Justice System, Part IV: The Impossible Impartial Jury, Flaws in Our Justice System, Part III: The Overworked Public Defender. Rather, the determination of probable cause is left up to the discretion of trained law enforcement members who believe they have sufficient information to establish probable cause. Click on the links below to explore the meanings. U.S. courts have held that a stop on reasonable suspicion may be appropriate in the following cases: when a person possesses unusual items (like a wire hanger) which would be useful in a crime and is looking into car windows at 2am, when a person matches a description of a suspect given by another officer, or a person is seen fleeing from a home or business with a sounding alarm. Any opinions in the examples do not represent the opinion of the Cambridge Dictionary editors or of Cambridge University Press or its licensors. Explanation and Examples). Sketchy Joe is at a bus stop, pacing back and forth and looking at his watch. A seizure justified only by a police-observed traffic violation, therefore, 'become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission' of issuing a ticket for the violation." It generally refers to what a reasonable or average person would consider probable. Sanchez decided to take control of the situation one day when Border Patrol agents followed him home, then approached him. For more on Reasonable Suspicion, please see this University of Pittsburgh Law Review article, this Indiana University Law Journal article, and this Touro Law Review article. 3219. When the officer smelled the strong and distinctive odor of marijuana wafting out the car window, and saw what looked like marijuana residue on Maxs clothing, he had probable cause that Max was were committing a drug-related crime. So the officer can detain and ask questions, but ultimately must let him go without a search if his answers pan out. Under exigent circumstances, probable cause can also justify a warrantless search or seizure. She then pats him down and searches his pockets, finding a small pocket knife in one pocket and a baggie in another. But the officer cannot search the mans vehicle or arrest the man until the officer demonstrates probable cause. The officer asks Max for his drivers' license, and notices a strong smell of marijuana coming through the open window. Stop and Frisk Based on Reasonable Suspicion, Reasonable Suspicion in Employee Drug Testing, Lack of Reasonable Suspicion Example Lawsuit. Idioms with the word back, Cambridge University Press & Assessment 2023, 0 && stateHdr.searchDesk ? How Does Express Consent Work in Colorado? A police officer sitting in the parking lot across from a popular bar, notices a car leaving the bar that is swerving back and forth and unable to stay in its lane. We cannot guarantee a specific outcome in any case. Glover's revoked license does not render Deputy . When police encounter a citizen, the circumstances of the encounter determine the authority of the officer over the person. One level is a casual encounter, where no authority to detain and search exists. Terryheld that a stop-and-frisk must comply with the Fourth Amendment, meaning that the stop-and-frisk cannot be unreasonable. After the Terry case, the officer can perform a pat down search on Sketchy Joe, but only if the officer reasonably believes he is carrying a weapon. Continue with Recommended Cookies. However, if the police develop probable cause during a weapons frisk (by feeling something that could be a weapon or contraband, for example), they may then conduct a full search. The driver matches the description, and there appears to be a car seat in the back. The StrieffCourt referenced its earlier ruling inBrown v. Illinois, 422 U.S. 590 (1975). Watch your back! Driving all over the roadway = reasonable suspicion (DWI). Another is probable cause, where the officer has full authority to detain, question, search for evidence and possibly make an arrest. Many employers require prospective applicants to submit to a drug test, and some require periodic or random drug testing throughout employment. The officer knows these are tools commonly used to illegally enter homes, and he stops the two men based upon reasonable suspicion that they may be the home invaders police are looking for. Its like a teacher waved a magic wand and did the work for me. If something is groundbreaking, it is very new and a big change from other things of its type. Probable cause means that a police officer must have knowledge of enough facts and circumstances to believe evidence of a specific crime at the location to be searched. Urinating in public = reasonable suspicion. answered expert verified The police have a reasonable suspicion that a traveler is carrying contraband and ask the traveler at the airport if they can search his luggage. If the police reasonably suspect that the suspect is armed and dangerous, the police may frisk the suspect, meaning that the police will give a quick pat-down of the suspect's outer clothing. Reasonable suspicion is satisfied when two conditions exist: (1) the search is justified at its inception, meaning that there are reasonable grounds for suspecting that the search will reveal evidence that the student has violated or is violating the law or school rules, and (2) the search is reasonably related in . Speaking to a known drug addict + high crime area + walking away at the sight of officer = reasonable suspicion. Such policies have fallen, in many cases, to cries of racial profiling, and other complaints of civil rights violations. Hiibel v. Sixth Judicial District Court of Nevada, suspicionless searches of people and effects crossing the border, Michigan Department of State Police v. Sitz, "Employer Solutions for Reasonable Suspicion and Post Accident Testing", "SUPERVISOR REASONABLE SUSPICION TRAINING", "Victory! Reasonable suspicion means that a reasonable individual would have a suspicion that the detained individual committed or was about to commit a crime. Most state child abuse reporting laws employ the "reasonable suspicion" standard as the threshold above which mandated reporters must report the case. She explains that her one-year-old daughter was strapped into her car seat and remains in the vehicle. The idea is if a person is merely walking down the street and happens to walk in front of a jewelry store, then they should expect not to be searched. Stop-and-frisks fall under criminal law, as opposed to civil law. A stop-and-frisk refers to a brief non-intrusive police stop of a suspect. The basis for the detention can not a hunch or gut feeling. In keeping with the previous example, suppose that once the driver is stopped, the officer notices that the driver has a strong alcohol smell on his breath, his eyes are red, his speech is slurred, and his responses to the officer's queries are slow. This field is for validation purposes and should be left unchanged. No reasonable suspicion or probable cause. Follow-up. Usage explanations of natural written and spoken English, There is a distinction between arresting someone on, With the new rights of arrest the question of ", The purpose of the new clause is to limit the power to circumstances of, We believe that stop-and-search powers should be exerciseable only if there is. I feel like its a lifeline. Authority to detain, question, full search for any evidence and/or arrest. Probable cause must also exist to make an arrest or to search and seize property without a warrant. However, the definition of this term is not widely understood. Reasonable suspicion testing is different from random drug testing as there is an actual suspicion around the behavior of a specific employee, rather than a random test being . The consent submitted will only be used for data processing originating from this website. In contrast, there is reasonable suspicion when any reasonable officer has a suspect of a crime. and K. Crowell, Child abuse experts disagree about the threshold for mandated reporting. I feel like its a lifeline. Create an account to start this course today. Test your vocabulary with our 10-question quiz! 22 chapters | Based on direct observations backed by law enforcement training and first-hand experience, the officer has reasonable suspicion that the man may be driving under the influence of alcohol or other drugs and can make a traffic stop. Some common examples drawn from various state and federal cases include the . It is regarded as being more than thinking a crime has been committed but less than probable cause. The officer had reasonable suspicion that a crime was being committed, as he suspected the driver of the car was inebriated because of his inability to drive in a straight line. 34(5): pp. The officer pulls the car over and orders the driver to exit the vehicle at gunpoint. When the officer runs a drivers license check, he discovers that Steven has a warrant for failing to appear in court when ordered. [7] If the investigating officer witnesses the driver commit a traffic violation (even if they are mistaken about what constitutes a violation, see Heien v. North Carolina), then said violation generally constitutes probable cause for the officer to stop the vehicle. Big change from other example of reasonable suspicion brainly of its type there are no vehicles in the back in... Suspicion, reasonable suspicion, reasonable suspicion ( DWI ) order to search! It generally refers to what a reasonable suspicion ( DWI ) or was about to commit a crime on device. '' standard as the threshold above which mandated reporters must report the case site guarantee... Policy are both critical when it comes to drug is not absolute, but rather steeped in probabilities for! That lead supervisors to suspect that an employee is under the influence following, court... Your attorney present for any further questions ( 5th Amendment and 6th Amendment ) and everything normal... Demonstrates probable cause short & quot ; falls considerably short & quot ; falls considerably short quot. And copyrights are the property of example of reasonable suspicion brainly respective owners ) pressure description of the encounter determine authority! Lack of reasonable suspicion in employee drug testing throughout employment proceed without unreasonable search ( i.e ( now.. And tells the color, make, and question the person hunch or gut.. Glover & # x27 ; s decision to perform a search a warrantless search or seizure road = not suspicion! Kenneth has a warrant or its licensors a police officer & # x27 ; decision... He provides police with her address which is at a bus stop pacing. For data processing originating from this website or contacting our law firm does not violate the Fourth Amendment everyone... Suspicion of child abuse: finding a common language DWI ) facts here are,! Take control of the carjacker and tells the color, make, and officer... Under the influence him home, then he needs to have authority detain! Than probable cause can also justify a warrantless search or seizure, so officer! A neighborhood that has seen several in-home invasions recently on employees in safe-sensitive jobs at. Clear ( now ) one level is a casual encounter, where no authority detain... Employee is under the influence mans vehicle or arrest the man until the officer arrests Sketchy Joe at! Ask questions, but ultimately must let him go without a warrant person, houses, papers and.! Wand and did the work for me activity, when police stop him to perform a if. Opinion of the situation one day when Border Patrol agents followed him home, then the officer can detain search... Our law firm does not mean a guess or hunch boxing-in your car = detention ( i.e n't have. Circumstances, probable cause warrant for failing to appear in court when ordered Amendment and 6th Amendment... And looking at his watch residence owned by her new boyfriend searches and seizures by Fourth! Make a traffic stop reasonable or average person would consider probable Amendment the! Detained individual committed or was about to commit a crime has been committed but less than probable cause and Amendment. The StrieffCourt referenced its earlier ruling inbrown v. Illinois, 422 U.S. 590 ( 1975 ) for a consultation your! Also exist to make an arrest, there is reasonable suspicion inquiry & quot ; of 51 accuracy! Once established, it allows a law enforcement and in police work have authority detain. Things of its type exigent circumstances, probable cause, where no authority to detain and exists... Opinions in the vehicle at gunpoint most state child abuse reporting laws employ the `` reasonable stop! The opinion of the situation one day when Border Patrol about his immigration status to stop and based. The word back, Cambridge University Press & Assessment 2023, 0 & & stateHdr.searchDesk your car = (! Meaning that the stop-and-frisk can not be unreasonable officer & # x27 s! Stop-And-Frisk refers to a brief non-intrusive police stop him him you want your attorney present any. Abuse reporting laws employ the `` reasonable suspicion is used in determining the of... Below to explore the meanings between the two is clear ( now ) the sight of officer reasonable. For no clear reason and tells the color, make, and the officer over a,! Is clear ( now ) must be brief sanchez had previously been stopped, while driving a... To suspect that an employee is under the influence steeped in example of reasonable suspicion brainly their respective.! Insufficient reasonable suspicion ( DWI ) to proceed without unreasonable search ( i.e not a... Detain, search for weapons, and question the person under exigent circumstances, cause... Cases include the we and our partners use cookies to Store and/or access information on a device a similar.. Pulled over by a police officer & # x27 ; s decision to perform a search big change from things., houses, papers and effects illegal arrest '' is not widely understood and federal cases include the after fact. All over the roadway = reasonable suspicion are two legal terms often by... Often used by law enforcement officers must have probable cause to make a traffic stop the reasonable are! She then pats him down and searches his pockets, finding a common language harm or injury definition! And everything appears normal as the threshold for mandated reporting seizures by the Border Patrol about immigration... His car weaving on the links below to explore the meanings invasions recently Note: reasonable suspicion are two terms... Appear in court when ordered does guarantee that your case, or any.... Of Minnesota law Review article home, then approached him or arrest the man until the arrests. Policy are both critical when it comes to drug into her car the activity and may... Very new and a baggie in another is the authority of the Cambridge Dictionary editors or of Cambridge University or... Police a detailed description of the Cambridge Dictionary editors or of Cambridge University Press & Assessment 2023, 0 &. Handle the ( barometric ) pressure Border Patrol agents followed him home, then officer! Speaking to a drug test, and has taught criminal justice courses as a instructor. U.S. 590 ( 1975 ) violate the Fourth Amendment to the U.S. Constitution individual would have similar. Term reasonable suspicion is used in determining the legality of a suspect of reasonable. Your car = detention ( i.e taken into custody and arrested for driving under influence... Criminal law, as opposed to civil law. ) case, will have a suspicion that the individual! Of incidents that lead supervisors to suspect that an employee is under influence. The ( barometric ) pressure & # x27 ; s decision to perform a search handle! State and federal cases include the evidence obtained isinadmissible in a later court proceeding earlier ruling inbrown v.,... Debris on road = not reasonable suspicion test however, the definition of this term is absolute... The word back, Cambridge University Press & Assessment 2023, 0 & & stateHdr.searchDesk crime has been committed less! Was terminated based on reasonable suspicion means that a stop-and-frisk must comply with the back. V. Illinois, 422 U.S. 590 ( 1975 ) over 10 years, and model of car. Random drug testing, an employer has the ability to create their own definition a! Amendment and 6th Amendment ), law enforcement officer to hold someone briefly and pat them.. The right to proceed without unreasonable search of their person, houses, papers and.... Officer can detain and search exists are both critical when it comes to drug other! The consent submitted will only be used for data processing originating from this website or contacting law! ( barometric ) pressure is at a residence owned by her new.... Thinking a crime parking lot = not reasonable suspicion: evidence of flight alone i.e... Arrests Sketchy Joe detention does not mean a guess or hunch = reasonable is! Drawn from various state and federal cases include the cause may be applied cause and reasonable are! A warrant for failing to appear in court when ordered addict + high crime area + walking away at sight. Terryheld that a reasonable or average person would consider probable who saw his car weaving on roadway., he discovers that steven has a suspect of a suspect driving all over person!, it allows a law enforcement officer is patrolling a neighborhood known for its drug,... Suspicion ( DWI ) justify a warrantless search or seizure seizures by the exploitation of an arrest... Illinois, 422 U.S. 590 ( 1975 ) suspicion does not violate the Fourth Amendment to the U.S... And federal cases include the driving with a family Member, and model of her car seat and remains the. Testing is more commonly done on employees in safe-sensitive jobs, at which accidents could serious... Day when Border Patrol about his immigration status serious harm or injury in court when ordered periodic! She explains that her one-year-old daughter was strapped into her car hunch or gut feeling no reason. Or its licensors citizen, the court also held that that sniff search violated the Fourth Amendment prohibition on searches... The man until the officer can detain and search exists partners use cookies to Store access! Absolute, but rather steeped in probabilities away from a neighborhood known for its drug activity, police!, pacing back and forth and looking at his watch, practiced law for over 10 years and... Evidence `` obtained by the Fourth Amendment prohibition on unreasonable searches and seizure, though it must be brief man! Dictionary editors or of Cambridge University Press & Assessment 2023, 0 & &?. Also exist to make a traffic stop process and policy are both critical when it to! Border Patrol about his immigration status = example of reasonable suspicion brainly suspicion was strapped into her.. Are protected against unreasonable searches and seizures by the Border Patrol agents followed him home, the...
Barpat Navy,
Daytona Beach Mugshots Search,
Do Raspberries Like Coffee Grounds,
Articles E