standards of decision."[920] Without explanatory opinion,
Chief Justice Vinson and Justices Burton and Reed dissented in all three
cases.

Unreasonable Searches and Seizures

In National Safe Deposit Co. _v._ Stead,[921] decided in 1914, the Court
unequivocally declared that an unreasonable search and seizure committed
by State and local officers presented no federal question, inasmuch as
the Fourth Amendment does not apply to the States. Prior to that date,
the Court has passed upon this question obliquely in only a few
decisions,[922] in one of which it conceded for the sake of argument,
but without so deciding, that the due process clause of the Fourteenth
Amendment embraces in its generic terms a prohibition against
unreasonable searches. In two of these earlier cases the Court sustained
as consistent with due process the power of a State, in investigating
the conduct of corporations doing business within its limits, to demand
the production of corporate books and papers. The call for such papers
was deemed not to have been rendered unreasonable because, at the time
of the demand therefor, the corporation affected either temporarily or
permanently kept such documents in another jurisdiction. Nor was the
validity of the order to produce such materials viewed as having been
impaired by the fact that it sought to elicit proof not only as to the
liability of the corporation but also, evidence in its possession
relevant to its defense.

In its most recent opportunity to review the question whether the due
process clause of the Fourteenth Amendment precludes admission in a
State court of relevant evidence obtained by an unreasonable search and
seizure,[923] the Court apparently ruled in the negative; but Justice
Frankfurter, speaking for the majority, did not limit himself to a
repetition of the conclusions stated by him in Adamson _v._
California;[924] namely, that the due process clause of the Fourteenth
Amendment did not incorporate the first eight Amendments of the
Constitution, and, conformably to Palko _v._ Connecticut,[925] exacts no
more from a State than is "implicit in 'the concept of ordered
liberty.'" He also proclaimed that: "The security of one's privacy
against arbitrary intrusion by the police--which is at the core of the
Fourth Amendment--is basic to a free society. It is therefore implicit
in 'the concept of ordered liberty' and as such enforceable against the
States through the due process clause."