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When we condone officers use of these devices without adequate cause, we give them reason to target pedestrians in an arbitrary manner.[107] These fears certainly accord with the realities facing many heavily policed communities.[108] Defendants and attorneys we interviewed described a litany of explanations offered by the police to justify stopping a person on the street or in a car, many of which appeared to them to be pretextual: failure to signal, driving in the left lane on an interstate, driving with a license plate improperly illuminated or with a window tint that is too dark, walking in the opposite direction of traffic, failing to cross the street at the crosswalk or a right angle, or walking in the street when a sidewalk is provided.[109] In many jurisdictions, these reasons are not sufficient in themselves to allow the officer to search the person or vehicle.[110] Yet in police reports we reviewed for several cases in Texas and Florida, officers stopped the defendant for a traffic violation, did not arrest for that violation, but conducted a search anyway

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