In the years following the Court 's ruling in Drayton , scholars have offered a range of opinions about the case 's impact and significance . Some analysts have suggested that '' Drayton '' reflects a concern among members of the Court for " ensuring that individuals retain the power to stand up for their rights " . However , other scholars , such as Tracey Maclin , argue that Justice Kennedy improperly assumed that citizens will always feel free to refuse consent , and that many citizens cooperate with the police because of " fear of police reprisal if they do n't " . Criminal law scholar Janice Nadler commented that Justice Kennedy 's conclusions were products of " intuitive reflections on his and the other Justices ' own experience and about the imagined experience of other citizens " . Additionally , Ric Simmons criticized the Court 's ruling for failing to reflect the realities of " real-life confrontations occurring on the street " between citizens and law enforcement . Other scholars , such as Thomas W. Hughes and Joshua Fitch , argued that the Court 's decision in '' Drayton '' would impact the balance between individual liberties and heightened national security interests in the wake of the September 11 attacks
September 11 attacks
September 11 attacks
United States v. Drayton