Abstract: The fourth amendment is the Supreme Court's tarbaby: a mass of contradictions and obscurities that has ensnared the "Brethren" in such a way that every effort to extract themselves only finds them more profoundly stuck.In 1971 Justice Harlan called for "an overhauling" of fourth amendment law, 1 but this has not occurred.Instead, the Court has simply continued to struggle with the same problems, finding "solutions" which sow ever more litigation and confusion.More than a decade ago, Professor Weinreb cited the fact that in the preceding five Terms (1968Terms ( -69 to 1972-73) -73) the Court had rendered sixteen major opinions interpreting the fourth amendment, illustrating that the "body of [fourth amendment] doctrine . . . is unstable and unconvincing." 2 In the past five Terms (1979Terms ( -80 to 1983-84) -84) the Court has decided thirty-five cases involving the fourth amendment.In seven of these there was no majority opinion.In the seventeen cases decided in the last two years, the Supreme Court has never reached the same result as all lower courts and has usually reversed the highest court below, rendering a total of sixty-one separate opinions in the process.Thus it is apparent that not only do the police not understand fourth amendment law, but that even the courts, after briefing, argument, and calm reflection, cannot agree as to what police behavior is appropriate in a particular case.