Reasonable suspicion can be found in the first clause of the Fourth Amendment (Siegel, 2012). It is considered the evidence necessary to prove that a crime has been committed (Siegel, 2012). There is no exact minimum required, but judges have held that it must be below the level of proof necessary to prove beyond a reasonable doubt the guilt needed in a trial (Siegel, 2012). This part of the Fourth Amendment is also included in the foggy interpretation. There is bias as to how this clause should be read and understood (Bloom, 2003). A large majority of courts express a preference for the reasonableness clause and this must be read separately from the agency clause (Bloom, 2003). Researchers believe that this interpretation of the clause gives the government greater discretionary power than the original authors intended (Bloom, 2003). The Court continues to use historical context in its recent decisions (Bloom, 2003). In Wilson v. Arkansas (1995), Justice Clarence Thomas noted that to make sense of the term reasonableness, it is helpful to determine the intent of the authors (Bloom, 2003). In Kyllo v. United States (2001), the court continued to recognize the importance of the home; for example, announcing oneself before a home search to determine Fourth Amendment reasonableness (Bloom, 2003). In Atwater v. City of Largo Vista (2001), Justice David Souter looked to the history of the Fourth Amendment to determine an officer's authority to make a warrantless arrest for a misdemeanor not involving a violation of peace (Walker, 2003, p. 239-252). Judge Souter concluded that the evidence suggested that the framers did not contemplate a warrantless misdemeanor arrest, unaccompanied by actual o...... middle of paper ...... rest-warrants. Georgetown Law Journal, 71(2), 342-369. Accessed March 20, 2014, from http://df9uh2wc8b.search.serialssolutions.com/?ctx_ver=Z39.88-2004&ctx_enc=info:ofi/enc:UTF-8&ctx_tim=2014-03-31T00%3A07%3A03IST&url_ver=Z39. 88-2004&url_ctx_fmt=infofi/fmt:kev:mtx:ctx&rfr_id=info:sid/primo.exlibrisgroup.com:primo3-Article-gale_ofa&rft_valSiegel, L. and Worrall, J. (2012). Introduction to Criminal Justice (14th ed.). Belmont, CA: Wadsworth. Stephens, OH and Glenn, R.A. (2006). Unreasonable searches and seizures rights and freedoms provided by law. Santa Barbara, CA: ABC-Clio. Walker, J. and McKinnon, K. (2003). Atwater v. City of Lago Vista: Police authority responsible for making warrantless misdemeanor arrests. Journal of Contemporary Criminal Justice, 19(2), 239-252. Accessed March 20, 2014, from http://ccj.sagepub.com.ezproxy.fiu.edu/content/19/2/239.full.pdf+html