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This Court should adopt the Sixth Circuit test, as adopted by the DC Circuit, because the police officers will then have a concrete rule to follow and to apply to situations where civilians are able to expect protection. Brian D. Jones, Note, Keep Closed Containers Closed: Resolving The Circuit Split In Favor Of Individual Privacy, 97 Iowa L. Rev. 303, 318 (2011). This adoption would allow people to rest assured that their expectation of privacy will be observed and protected by police officers, creating an environment conducive to all parties involved. The right to privacy is at the forefront of the issues citizens are concerned with. An adoption of the requirement to clarify ambiguity will allow citizens to vest confidence in the court and

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