The Volokh Conspiracy

The First Amendment and Information Gathering:

Prof. Mark Kleiman (The Reality-Based Community) and Prof. Michael Froomkin (Discourse.net) rightly condemn this move by some New York officials:

Richard Falkenrath, the NYPD's deputy commissioner for counterterrorism, ... and Mayor Michael Bloomberg have asked the City Council to pass a law requiring anyone who wants to own [machines that detect traces of biological, chemical, and radiological weapons] to get a permit from the police first. And it's not just devices to detect weaponized anthrax that they want the power to control, but those that detect everything from industrial pollutants to asbestos in shoddy apartments. Want to test for pollution in low-income neighborhoods with high rates of childhood asthma? Gotta ask the cops for permission. Why? So you "will not lead to excessive false alarms and unwarranted anxiety," the first draft of the law states.

Last week, Falkenrath made his case for the new law before the City Council's Public Safety Committee, where Councilman Peter Vallone introduced the bill and chaired the hearing. Dozens of university researchers, public-health professionals, and environmental lawyers sat in the crowd, horrified by the prospect that if this law passes, their work detecting and warning the public about airborne pollutants will become next to impossible. But Falkenrath pressed on, saying that unless the police can determine who gets to look for nasty stuff floating in the air, the city would be paralyzed by fear.

"There are currently no guidelines regulating the private acquisition of biological, chemical, and radiological detectors," warned Falkenrath, adding that this law was suggested by officials within the Department of Homeland Security. "There are no consistent standards for the type of detectors used, no requirement that they be reported to the police department—or anyone else, for that matter—and no mechanism for coordinating these devices.... Our mutual goal is to prevent false alarms ... by making sure we know where these detectors are located, and that they conform to standards of quality and reliability." ...

As the opposition mounted, Vallone pulled the proposed legislation just before the meeting's end and agreed to give it a second look.... He and his colleagues will try to accommodate all the concerns when they redraft the bill, he said, but one way or another, the cops are going to have this new power....

This is the very model of government paternalism, and likely counterproductive government paternalism at that. But Mark asks: Does it violate the First Amendment, because it deliberately interferes with information gathering?

I think the answer has to be: Nobody knows. The Supreme Court has said surprisingly little about restrictions on information gathering (as opposed to restrictions on information dissemination, which is what most of the Court's Free Speech/Press Clause caselaw is about).

We do know that generally speaking there's no First-Amendment-based information gathering defense to generally applicable laws, such as bans on travel to Cuba and the like. We also know that there's generally no First Amendment right of access to information that's in the government hands (except for a historically sanctioned presumptive right of access to criminal trials, which lower courts have reasonably extended to civil trials and to most court filings in civil and criminal cases).

But here the government is proposing the licensing of certain products precisely because of a fear that the products will be used to gather information, and then to disseminate the information in ways that the government claims might be misleading. That sure sounds bad, because the government's rationale is frankly concerned with the communicative impact of the speech that will eventually flow from use of the devices.

Moreover, the fear isn't just that the devices and the speech they facilitate will infringe privacy (a rationale for banning certain forms of information gathering, such as unauthorized recording of conversations, and potentially even the distribution of certain kinds of eavesdropping restrictions). Rather, it's that it will lead to speech that will mislead and frighten the citizenry into doing foolish things — a classically disfavored rationale in First Amendment law.

So I think there's a perfectly credible First Amendment argument against any such ban — as well as lots of first-rate policy arguments (for some plausible-seeming examples, see this American Industrial Hygiene Association letter). But there's no Supreme Court caselaw squarely confronting this subject, so predictions are hard to make (though if anyone can point me to some useful lower court caselaw on the subject, I'd love to read it).

UPDATE: Thanks to John Wilson from the UCLA Law Library, I now have the text of the proposed amendment:

33yearprof:
I wouldn't live in or visit NYC if it was the last city on Earth. I was there in 1975 for 2 days. I saw nothing that would tempt me back. I'm happy in fly-over land.
1.30.2008 6:56pm
Fub:
§ 10-802 Permits for possession or deployment of biological, chemical and radiological detectors.

a. It shall be unlawful for any person to possess or deploy a biological, chemical or radiological detector in the city of New York unless such person holds a valid permit therefor, provided that the commissioner in his or her discretion may exclude by rule any class or type of biological, chemical or radiological detector that shall not require such permit because requiring a permit therefor would not further the purposes of this chapter.
Let us hope that in his infinite wisdom, the commissioner will exercise his discretion to permit the possession of noses and related olafactory organs. Under the definition in § 10-801(c) &(e), they are biological and chemical detectors.

When noses are outlawed, only outlaws will have noses!

On the bright side, it won't be difficult to spot someone from New York City.
1.30.2008 7:37pm
RMCACE (mail):
This situation has come up before.

http://www.msnbc.msn.com/id/18924801/

There the Dept. of Ag. sought to keep a meatpacker from testing his own cattle for mad cow. There are a lot of distinguishing features of that case, as a policy matter. After all, no one would want a false positive more than the meatpacker. No First Amendment issues discussed, however.

517 F.Supp.2d 8
1.30.2008 8:08pm
Bender (mail):
The police in NYC already control access and ownership of firearms (a constitutionally protected right). Why shouldn't they control access to these devices, which is not constitutionally protected? Am I the only one to note that there's a certain amount of hypocrisy and amour propre involved in this complaint by persons who've shown either indifference towards or active support for the elimination of the right to keep and bear firearms in NYC?
1.30.2008 8:25pm
therut:
I agree. Where is my right to acquire a firearm in NYC without a permit or in the entire state for that matter. Some people say that makes me a gun nut and a 2nd amendment absolutist. Well I do not know what to call someone who sees everything as a 1st amendment issue. I disagree with Bloomberg. Oh how I wish the 2nd amendment was supported half as much as the 1st. LOL.
1.30.2008 9:00pm
Cecilius:
"Want to test for pollution in low-income neighborhoods with high rates of childhood asthma? Gotta ask the cops for permission. Why? So you 'will not lead to excessive false alarms and unwarranted anxiety,' the first draft of the law states."

As a toxic tort defense attorney, I've seen advocacy groups working with plaintiffs' attorneys doing shoddy and misleading testing for pollutants in neighborhoods as part of public relations ploys to pressure defendants to settle tenuous claims for personal injury and property damage. Just having some of these people show up to your house causes public outcry: "Ma'am we have reason to believe that there are tons of PCBs buried throughout your yard and gardens due to the horrible, illegal behavior of company X - mind if we test with this doohickey to see how badly you and your children are being poisoned?" Most of the "testing" is done so unprofessionally and shoddily that it annoys me to no end (and if the tests turn up nothing, just lie - the reporters won't try and verify it). But HOLY COW!, I couldn't even imagine requiring city permits to do this stuff! I think the claim that requiring a permit will make "detecting and warning the public about airborne pollutants ... next to impossible" is a little bit over-the-top, but it will certainly discourage some of this work.

Okay, so there will or can be false alarms and unwarranted anxiety - if the testers are actually wrong, but what's the cost of not doing this type of testing when it's needed? As much as the practices of some perturb me (e.g., intentional false positives to garner publicity), I just can't see a strong enough reason to justify government intervention.
1.30.2008 9:46pm
Eugene Volokh (www):
Bender, therut: I'm certainly no foe of the right to bear arms, but I don't think your analogy works. People who support gun bans take the view that guns kill (which they do) and that banning guns will therefore diminish the death toll (which I think is a factual mistake, but not an implausible one). Detectors don't kill, and the asserted harm stems not from people shooting each other, but from the public supposedly being misled and unduly frightened -- a much more attenuated causal connection than the gun death connection.
1.30.2008 10:18pm
Elliot123 (mail):
Would police permission for carrying a cell phone reduce false alarms?
1.30.2008 10:31pm
Bill Poser (mail) (www):

Any person deploying a biological, chemical or radiological detector shall immediately notify the police department if such detector indicates an alarm, notwithstanding whether the person holds a permit for such detector, by following such procedures as are prescribed by rule of the commissioner and/or are included as a term of the permit itself.

The above provision requires people to incriminate themselves. Isn't this a Fifth Amendment problem?
1.30.2008 10:33pm
zb:
Elliot123:
Um yes, but only if your cell phone carries these types of detectors.

Eugene:
First responders may also be misled by reports from unknown detection systems. Effective response to alarms from unknown systems might be the real issue here.

Bill:
I hope not. Perhaps the proposed law needs a "good Samaritan" clause. If your use of an illicit unregistered rad/chem/bio detector saves the city, the city should reward you by not prosecuting.
1.31.2008 12:11am
Lev:
Haven't there been any cases about "journalists" "right to access" proceedings and such under some first amendment theory? Or am I misremembering.
1.31.2008 2:21am
Darrin Ziliak:
The problem here is that smoke alarms (along with CO detectors) are 'biological, chemical or radiological' detectors.

Of course these are the detectors that the Commissioner would (hopefully) use his discretion to waive the permit requirements.
Though this is Bloomberg and common sense is purely optional with him, so who knows.

'Ma'am, I need to see your permit for that First Alert.
Maybe they could indict William Conrad as a co-conspirator. :)
1.31.2008 5:34am
fishbane (mail):
As someone actually impacted by this statute (I liive in NYC, and own a geiger counter), I'd just like to make the general point that this is of a kind with other NYC foolishness. Harassment for taking pictures in public is common, even at a time when surveillance cameras are getting all but ubiquitous. I've found that having my "pro" looking camera makes me a target - walking around with an SLR with a decent lens attracts much more attention from rent-a-cops and police than I get for using a point and shoot. And let's not forget the (abandoned, I think) attempts to license the use of a tripod for more than 10 minutes.

I wonder if there would be support behind a "freedom to perceive" statute. As the 4th amendment continues to be eroded, ubiquitous surveillance is installed and people are being charged with infringing the privacy of police making arrests in public, defending the right to sample visible light, radiation levels or anything else becomes more important. Wanting to play with my geiger counter probably won't garner much support ("that's weird. Why do you need to do that?"), but photography might.

OTOH, discouraging tourists from coming to NYC would be a good thing - the sidewalks in Midtown would be much easier to navigate without the folks who don't know how to walk.
1.31.2008 5:54am
Just Dropping By (mail):
(A) The rationale that private ownership of detection equipment should be banned because of the risk of "excessive false alarms and unwarranted anxiety," sounds like it could have come word-for-word from a Chinese Communist official.

(B) Does anyone else think "Richard Falkenrath" would make an excellent name for a James Bond supervillain?
1.31.2008 9:15am
Temp Guest (mail):
Professor Volokh: I understand your point but we all need to understand that the moment we accede to the government's control of one right we have encouraged the government to encroach upon other rights that we may hold more dearly.
1.31.2008 9:18am
Pol Mordreth (mail):
RMCACE

This situation has come up before.

http://www.msnbc.msn.com/id/18924801/

There the Dept. of Ag. sought to keep a meatpacker from testing his own cattle for mad cow. There are a lot of distinguishing features of that case, as a policy matter. After all, no one would want a false positive more than the meatpacker. No First Amendment issues discussed, however.



Actually, once you get to responsible reporting of that case, you learn that the FDA and USDA concerns weren't about false positives, but false negatives. The tests that we have for BSE are less than 10% accurate at the age of a slaughtered steer. We slaughter steer for meat at around 16 - 20 months. The BSE test is only accurate after about 30 months. the USDA and FDA regs require a percentage of animals from each season not be slaughtered, but allowed to grow old and those are the ones that are tested. Creekstone Farms wanted to label its beef with "100% tested" or some such, and it wouldn't mean a thing.
http://www.foodproductiondaily-usa.com/news/ng.asp?id=77014

http://ec.europa.eu/food/fs/bse/bse21_en.html

Respectfully,
Pol
1.31.2008 11:23am
MXE (mail):
Michael Bloomberg is such a vile, un-American POS. The fact that people still occasionally talk about him as a potential independent presidential candidate is such a laugh.

I mean, honestly, who on Earth would vote for this guy?
1.31.2008 12:45pm
Orielbean (mail):
Falkenrath would be a great villan name.
1.31.2008 12:49pm
BR (mail):
"There are no consistent standards for the type of detectors used, ... making sure ... they conform to standards of quality and reliability."

There are no standards of which I'm aware, and I'm in this line of business, serving an organization that owns fleets of such detectors, both government-issue and scientific.

I don't think such standards can be met unless they are so conservative as to be meaningless. Legislative demand for instruments on this order of sensitivity-vs-reliability is another manifestation of the CSI effect. Even the cops' instruments will suffer the same frailties, so they deserve no favored position in law, either to trust their own instruments or distrust anyone else's.

The operators of these devices take alarms and indications with a grain of salt, by crossmatching with alternate instruments, rechecking or recalibrating the instrument, taking multiple readings, and eventually forwarding a carefully-prepared sample to a NIST-traceable lab operated by an MS in chemistry, biology, or health physics.
1.31.2008 1:43pm
H. Blix:
As a native New Yorker who moved out of NYC (and the state of New York) only seven months ago (still selling our house there) this legislation is par for the course for the city council. Full disclosure, I worked for a time in one city councilman's office, doing analysis of proposed legislation. The sheer amount of dub legislation (much of it facially unconstitutional) proposed and which, unfortunately, ultimately passes boggles the mind. And as an aside to the poster on the 2nd Amendment, aving left NYC I still have my NYC Permit to Possess Rifles and/or Shotguns in my drawer - (for which I had to pay over $200, get photographed, fingerprinted and wait for the city to issue, all for the "privilege" of purchasing and possessing a long gun, subject, of course, to the city's further strictures on magazine capacity [no more than 5 rounds, which eliminated 98% of the .22 rifle I was interested in].

In sum, a pox upon New York City. I voted for Bloomberg twice - as the lesser of two evils given the folks he ran against - but would NEVER vote for him in a national election.
1.31.2008 2:15pm
TM Lutas (mail) (www):
Why limit penumbras and emanations to the 1st amendment? Since CBW kits are often used by the military, why wouldn't there be a 2nd amendment right to have a geiger counter for the purpose of defense against WMD assault?
1.31.2008 8:39pm
BR (mail):
Editing myself above: "I don't think such standards can be met" I meant to say "developed."

Qualifying myself above: "I don't think such standards can be xxx" for detectors for chemical and biological warfare agents.

Reliable detectors for ionizing radiation can be made inexpensively, and are increasingly commonplace in public safety settings. Chem and bio, not yet, maybe with lots of nanotech. Any venture capitalists note: I'd like to propose my gas-chromatograph-on-a-chip; contact me offline ;^)

TM: "often used"? How about "routinely." Every Soldier is issued and test-fitted with a protective mask, and is trained to don it quickly, recognize agent symptoms, and carry out common and specialized tasks in a contaminated environment.

In the 2nd Amendment context: CBRN has been used in counterinsurgencies, far more C than B, R, or N. US doctrine predicts that enemies are less likely to use it against troops trained and equipped to defend against it. So CBRN defense has a legitimate purpose in a well-regulated Militia.
1.31.2008 9:39pm
AD:
The analogies to firearms and BSE testing are interesting, but has anyone looked at the analogy to bans on radar detectors in various states? These devices work similarly in passively detecting radar beams being targeted at you. Considering the prevalence of these laws, I imagine the courts have upheld the bans against First Amendment challenge.
2.1.2008 11:32am
BR:
AD: radar detectors can be assumed to be useful only to avoid enforcement of speeding laws. Makers of these detectors claim there's a legitimate purpose behind that, of protecting yourself against faulty or uncalibrated radar detectors, or an error-prone technology, but overall the initial impression of a radar detector's purpose is to know where and when a cop is running a speed trap.

Detectors of substances that are hazardous to one's health have an obvious legitimate purpose regardless of who has them. They don't create a hazard. Only in extreme circumstances would such detectors be used to commit a crime.

I don't see the analogy, at least in terms of intent.
2.2.2008 12:17am