Note:
William G. Ross, Constitutional Law—Search and Seizure—Court-Ordered Surgical Removal of a Bullet from an Unconsenting Defendant for Evidentiary Purposes Held Reasonable Under the Fourth Amendment. Crowder v. United States, 543 F.2d 312 (D.C. Cir. 1976), 55 TEXAS L. REV. 147 (1976).
 

Abstract:
This note discusses Crowder v. United States, a case in which the appellate court approved court-ordered surgery for the removal of a bullet for evidentiary purposes as a reasonable search and seizure under the fourth amendment. The author criticizes the majority for considering only the procedural reasonableness used by the prosecution to authorize the surgery rather than fourth amendment reasonableness in the search for evidence. Such a decision ignored the individual's right to privacy and dignity, failed to recognize the questionable necessity of such a surgery to successful crime-fighting, and opened the door to an unknown path, allowing judges to decide difficult medical questions, for which they may not have the proper expertise. Without adequate standards to guide them, judges could by mistake easily authorize procedures with fatal consequences.