U.S. Const. amend. IV (“The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”)

compare to 4th Amend.

Penn. Const. art. I, sec. 8.

State v. Ringquist, 433 N.W.2d 207

State v. Herrick, 1999 ND 1 (discussing origins of clause and links to Pennsylvania provision)

State v. Hendrickson, 2019 ND 183 (Crothers, J., concurring)

Cooley, at 365-74

The comma after seizures