people so long as the interaction is brief. In the Delgado case, the Court held that the factory survey was not a seizure of the workforce, but instead an instance of “mere questing.” The presence of INS agents at the doors of the factory and the manner with which the workers were approached and questioned, the Court ruled, did not constitute a formal detention. Therefore the Fourth Amendment did not apply. Background Factory Sweeps The Immigration and Naturalization Service has a history of conducting "factory sweeps" across the country in order to locate undocumented immigrant workers. While critics have claimed that these sweeps are largely ineffective and serve most often as media events, the INS maintains that they are an important tool for protecting U.S. jobs. These sweeps occur when the INS receives information that a certain business may be employing undocumented immigrants and the workers at the business are determined to fit such a profile, though, as in the case of INS v. Delgado, no specific individuals need be identified. Typically, 15 or 25 INS agents enter a place of business, surrounding workers and guarding exits, and proceed to question workers with regards to their citizenship status, often carrying those suspected of being undocumented away in handcuffs. As can be expected, these raids can cause considerable stress for the workers; one woman subjected to this procedure is even quoted as saying she was afraid "because if I leave and they think I don't have no papers and they shoot me or something." Despite the fear-inducing nature of the sweeps, the Supreme Court maintained that those subjected to them have in no way been detained or seized, as they are technically free to go at any time and any "reasonable person" would realize this freedom. Terry v. Ohio In the case of Terry v. Ohio, the Supreme Court established a practical standpoint on “mere questioning”, effectively giving law enforcement officials the ability to speak with citizens, and even search them, in certain situations without necessarily being held accountable to the restrictions of the Fourth Amendment. In this case, an officer approached three men he suspected of casing a building for a robbery or stick up. He confronted them, questioned them, and for the purposes of his own safety, patted them down. The officer found that they were carrying concealed weapons, which were later used as evidence that they were about