A house divided: when state and lower federal courts disagree on federal constitutional rights

The variation underscored the challenge entailed in realizing the Supreme Court's expectation that the Fourth Amendment is "enforceable in the same manner and to like effect" nationwide. The article surveyed the many practical and theoretical ramifications of what Justice Scalia recently condemned as a "crazy quilt" of federal constitutional rights, generated by a single sovereign's judicial system -- the nation's federal circuit courts.