Arizona v mauro

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Arizona v. Mauro, 481 U.S. 520, 526 (1987). Here the officers both told the defendant that they possessed incontrovertible evidence of his involvement in the crime and offered to bring any cooperation on his part to the attention of the district attorney. They also told the defendant that he might wish to do some "soul-searching" or make peace ...Arizona v. Mauro, 481 U.S. 520, 529 (1987) ("Any statement given freely and voluntarily without any compelling influences is, of course, admissible in evidence." (quoting Miranda, 384 U.S. at 478)). The evidence here, however, does not show this type of coordination. After eliciting Mr. Patterson's confession-on a matter unrelated to the ...A comprehensive list of all case law citations in the Constitution Annotated alongside the Constitution Annotated essays in which the citations are located.xv table of contents preface.....v about the author.....ix selected federal constitutional provisions.....xi table of cases.....Arizona v. Mauro, 481 U.S. 520, 527 (1987). Thus, this Court should deny Graham’s petition. 2 A. The Proceedings Below Graham was convicted of hiring Walton to murder her daughter, Stephanie “Shea” Graham. A Russell County grand …

Arizona v. Mauro, 481 U.S. 520, 526 (1987). The "functional equivalent" of interrogation includes "any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.'ARIZONA v. MAURO CERTIORARI TO THE SUPREME COURT OF ARIZONA No. 85-2121. Argued March 31, 1987-Decided May 4, 1987 After being advised of his Miranda rights while in custody for killing his son, respondent stated that he did not wish to answer any questions until a lawyer was present. All questioning then ceased and respondent wasSee the Arizona State to Revised prove Statutes Mauro Both acted §§ 13-1203(A)(2) (2010) (assault), -2508(A) (2010) (resisting arrest). Thus, the anger and hostility expressed in his answers was relevant to the charges. ¶6 Second, the superior court found the doughnut question inadmissible under Arizona Rule of Evidence 403 because it was ...State, 533 So. 2d 418, 430 (Miss. 1988); Arizona v. Mauro, 481 U.S. 520 , 107 S. Ct. 1931, 95 L. Ed. 2d 458 (1987). It cannot be said that the explanation of lineup procedures to Wilson constituted words or actions reasonably likely to elicit an incriminating response.On March 31, 1980, Ohio State Highway Patrol Trooper C.J. Williams observed Richard McCarty’s vehicle weaving back and forth on Interstate Highway 270. He followed the car, pulled McCarty over, and asked him to exit the vehicle. Williams noticed that McCarty had trouble standing, and thus determined that he would charge McCarty with a traffic ...See Arizona v. Mauro, 481 U.S. 520, 528, 107 S. Ct. 1931, 1936, 95 L. Ed. 2d 458, 467 (1987). Interrogation, as used in Miranda, has been further explicated in Innis, as follows: [T]he term interrogation . . . refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant ...(Arizona v. Mauro (1987) 481 U.S. 520, 525-526 [95 L.Ed.2nd 458; 107 S.Ct. 1931], fn. omitted.) '"[I]nterrogation" under Miranda refers not only to express questioning, but also to any words or actions on the part of the police . . . that the police should know are reasonably likely to elicit an incriminating response from the suspect ...

City Of Indianapolis V Edmond O Drug Checkpoint Case O Ask To Produce License - CRIMINAL J5206. City of indianapolis v edmond o drug checkpoint case. School Louisiana State University; Course Title CRIMINAL J 5206; Uploaded By blantz71. Pages 14 This preview shows page 9 - 11 out of 14 pages.Case Details. Full title:STATE of Arizona, Appellee, v. William Carl MAURO, Appellant. Court:Supreme Court of Arizona. Date published: Feb 25, 1986. CitationsCopy Citations. …Jul 24, 2012 · 1 CA-CR 11-0408. 07-24-2012. STATE OF ARIZONA, Appellee, v. JOHNNY ANGEL MAURO, Appellant. Thomas C. Horne, Arizona Attorney General By Kent E. Cattani, Chief Counsel Criminal Appeals/Capital Litigation Section and Joseph T. Maziarz, Division Chief Counsel Criminal Appeals/Capital Litigation Section and Matthew H. Binford, Assistant Attorney ... Jackson (1986) Minnick v. Mississippi (1990) Arizona v. Roberson (1988) Davis v. U. (1994) Montejo v. Louisiana (2009) Maryland v. ... The dual principles of custody and interrogation Both are necessary before an advisement of rights is required Arizona v. Mauro (1987) Doyle v. Ohio (1976) Brecht v. Abrahamson (1993) Missouri v. ...

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Get Arizona v. Mauro, 481 U.S. 520 (1987), United States Supreme Court, case facts, key issues, and holdings and reasonings online today. Written and curated by real attorneys at Quimbee. Attention! Your ePaper is waiting for publication! By publishing your document, the content will be optimally indexed by Google via AI and sorted into the right category for over 500 million ePaper readers on YUMPU.Tison v. Arizona, 107 S.Ct. 1676 (1986) and concluded that "the amount of harm one causes does bear upon the extent of his per­ sonal responsibility." Booth, 107 S.Ct. at 2542 (emphasis added). In Tison, two brothers who planned and assisted in their father's escape from prison were sentenced to death because in the course of theirArizona, on November 25, 1935, asked leave to file a bill against California and the five other States of the Colorado River Basin, praying in effect for a partition of the right to appropriate in the future the waters of the stream not as yet appropriated. The defendants were ruled to show cause, December 9, 1935, 296 U.S. 552.

ARIZONA v. MAURO CERTIORARI TO THE SUPREME COURT OF ARIZONA No. 85-2121. Argued March 31, 1987-Decided May 4, 1987 After being advised of his Miranda rights while in custody for killing his son, respondent stated that he did not wish to answer any questions until a lawyer was present. All questioning then ceased and respondent wasIt comes from Miranda v. Arizona , a United States Supreme Court case that established that the government may not use statements stemming from "custodial interrogation" unless it is shown that "procedural safeguards" existed and were effective enough to offset the coercive nature of police-dominated interrogations. [3]Title U.S. Reports: Jenkins v. Anderson, 447 U.S. 231 (1980). Names Powell, Lewis F., Jr. (Judge) Supreme Court of the United States (Author)Id. See also United States v. Hendrix, 509 F.3d 362, 374 (7th Cir. 2007) (finding that “voluntary statements”- that is, statements that are not the result of “compelling influences, psychological ploys, or direct questioning”-are not subject to Miranda warnings) (citing Arizona v. Mauro, 481 U.S. 520, 529 (1987); United States v.Arizona v. Mauro (1987) Interrogation: third-party conversation is admissible. Texas v. Cobb-The 6th Amendment is offense specific ... However, in Missouri v. Seibert, if an interrogator uses a deliberate, two-step strategy, predicated upon violating Miranda during an extended interview, post-warning statements that are related to the substance ...¶41 It is clear from the record that Kooyman initiated the contact with Richards and that Richards was merely responding to Kooyman's inquiries. Kooyman was not being subjected "to compelling influences, psychological ploys, or direct questioning." Arizona v. Mauro, 481 U.S. 520, 529 (1987). He was not accused of committing the crime against L ...Arizona v. Mauro. Media. Oral Argument - March 31, 1987 ... Arizona . Respondent Mauro . Docket no. 85-2121 . Decided by Rehnquist Court . Lower court Arizona Supreme ... Justia › US Law › Case Law › Arizona Case Law › Arizona Court of Appeals, Division Two - Unpublished Opinions Decisions › 2018 › STATE OF ARIZONA v. MAURICE TYRONE HOLMES, JR. MAURICE TYRONE HOLMES, JR.

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A later Court applied Innis in Arizona v. Mauro 14 Footnote 481 U.S. 520 (1987). to hold that a suspect who had requested an attorney was not interrogated when the police instead brought the suspect's wife, who also was a suspect, to speak with him in the police's presence. The majority emphasized that the suspect's wife had asked to ...See Arizona v. Mauro, 481 U.S. 520, 107 S. Ct. 1931, 95 L. Ed. 2d 458, reh'g denied, 483 U.S. 1034, 107 S. Ct. 3278, 97 L. Ed. 2d 782 (1987). Following Stanley's confession, the state asserts that the purpose of Saravo's inquiry about the victims' location was to determine whether they might still be alive. The state argues this was proper ...Miranda rights protect suspects in custody from being coerced into giving incriminating evidence against themselves by law enforcement officials. Miranda v. Arizona, 384 U.S. 436, 444, 86 S. Ct. 1602, 1612, 16 L. Ed. 2d 694 (1966); see Arizona v. Mauro, 481 U.S. 520, 529-30, 107 SA later Court applied Innis in Arizona v. Mauro 14 Footnote 481 U.S. 520 (1987). to hold that a suspect who had requested an at to rney was not interrogated when the police instead brought the suspect's wife, who also was a suspect, ... Jump to essay-10 Edwards v. Arizona, 451 U.S. 477 (1981).See Arizona v Mauro, 481 US 520; 107 S Ct 1931; 95 L Ed 2d 458 (1987). Although defendant urges the suppression of the statements on the alternate grounds his arrest was illegal, the tape recording was improperly destroyed and the taping of the conversation was an alleged violation of MCL 750.539d; MSA 28.807(4), none of these claims have been ...A later Court applied Innis in Arizona v. Mauro 14 Footnote 481 U.S. 520 (1987). to hold that a suspect who had requested an attorney was not interrogated when the police instead brought the suspect's wife, who also was a suspect, to speak with him in the police's presence. The majority emphasized that the suspect's wife had asked to ...xxi table of contents united states supreme court chart.....iii preface to the fifteenth edition.....v a guide for readers: of form and substance.....The purpose of the strictures against selfincrimination is to prevent the police from using the coercive nature of confinement to 2 Id. See Miranda v. Arizona (1966), 384 U.S. 436, 474, 86 S.Ct. 1602. See Edwards v. Arizona (1981), 451 U.S. 477, 484-485, 101 S.Ct. 1880. 5 Rhode Island v.Las teorías legales modernas sobre los interrogativos y la voluntariedad de una confesión comenzaron a desarrollarse modernamente en el 1966 con la decisión de Miranda v.Arizona. 4 En Miranda, el Tribunal Supremo Federal sostiene que la Quinta Enmienda 5 requiere que la policía informe a un sospechoso criminal, antes de interrogarlo sobre derecho a permanecer callado y su derecho a ser ...The first Defendant, Ernesto Miranda (“Mr. Miranda”), was arrested for kidnapping and rape. Mr. Miranda was an immigrant, and although the officers did not notify Mr. Miranda of his rights, he signed a confession after two hours of investigation. The signed statement included a statement that Mr. Miranda was aware of his rights.

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Arizona v. Mauro, 481 U. S. 520, 481 U. S. 526 (1987). In Rhode Island v. Innis, 446 U. S. 291 (1980), the Court defined the phrase "functional equivalent" of express questioning to include "any words or actions on the part of the police (other than those normally attendant to arrest and custody) Page 496 U. S. 601Arizona v. Mauro, 481 U.S. 520, 526-27, 107 S.Ct. 1931, 1935 (1987). ¶16 Defendant argues that he did not voluntarily initiate the post-Miranda discussion. He contends the detectives employed the warrant as a tool to get him to talk. The warrant, in conjunction with McIndoo s statement that Defendant probably already knew what happened, caused ...LexisNexis users sign in here. Click here to login and begin conducting your legal research now.Justia › US Law › Case Law › Arizona Case Law › Arizona Court of Appeals, Division Two - Unpublished Opinions Decisions › 2009 › STATE OF ARIZONA v. JESUS MARIA DURAZO JESUS MARIA DURAZOU.S. Supreme Court Arizona v. Mauro, 481 U.S. 520 (1987) Arizona v. Mauro. Does. 85-2121. Argued March 31, 1987. Concluded Could 4, 1987. 481 U.S. 520Also with "its functional equivalent" (Arizona v. Mauro, 1987)—meaning any words or actions "reasonably likely to elicit an incriminating response from the suspect" Does not apply with "routine booking questions" (see: Pennsylvania v. Muniz, 1990) Physical evidence and routine booking question allowed without MirandaAnd, in the case Arizona v. Mauro, 481 U.S. 520 (1987), it was determined that a conversation between a suspect and a spouse, which is recorded in the presence of an officer, does not constitute the functional equivalent of an interrogation and is, therefore, admissible in court.Cf. State v. Mauro, 159 Ariz. 186, 766 P.2d 59 (1988) (jury could get necessary evidence from testimony, diagrams, and photographs as opposed to viewing crime scene); State v. Prewitt, 104 Ariz. 326, 452 P.2d 500 (1969) (when view of premises imma-terial to defense, defendant's request properly denied).Calculate how much you'll pay in property taxes on your home, given your location and assessed home value. Compare your rate to the Arizona and U.S. average. Calculators Helpful Guides Compare Rates Lender Reviews Calculators Helpful Guides...A later Court applied Innis in Arizona v. Mauro 14 Footnote 481 U.S. 520 (1987). to hold that a suspect who had requested an at to rney was not interrogated when the police instead brought the suspect's wife, who also was a suspect, ... Jump to essay-10 Edwards v. Arizona, 451 U.S. 477 (1981).In the case of Arizona V Mauro the Court held that a suspect who had requested for an attorney was not 'interrogated' by bringiing his wife instead who was also a suspect to speak with him in police presence. The dissent argued that the police had exploited the wife's request to talk to the husband in a custodial setting to create a sitiation ... ….

Recent Developments: Arizona v. Mauro: Police Actions of Witnessing and Recording a Pre- Detention Meeting Did Not Constitute an Interrogation in Violation of Miranda. Mark …In Ng Fung Ho v. White , the U.S. Supreme Court rules that the Fifth Amendment due process clause requires the government to hold a hearing before deporting a U.S. resident who claims to be a citizen, arguing that otherwise the person is deprived of liberty, and possibly in danger of losing property and life.Arizona v. Mauro, 481 U.S. 520 , 107 S. Ct. 1931, 95 L. Ed. 2d 458 (1987). Miranda warnings are inapplicable to voluntary statements which are not the product of interrogation.After a jury trial, Defendant was convicted of multiple drug offenses. The Supreme Judicial Court affirmed, holding (1) the suppression court did not err by denying Defendant's motion to suppress evidence seized from his apartment pursuant to a search warrant, as there was a substantial basis for the finding of probable cause to issue the search warrant; (2) the suppression court did not err ...Study with Quizlet and memorize flashcards containing terms like Agnelleo v. United States (1925), Arizona v. Fulminante (1991), Arizona v. Mauro (1987) and more.Attorneys for Plaintiff State of Arizona IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA STATE OF ARIZONA, Plaintiff, v. 3M COMPANY (f/k/a Minnesota Mining and Manufacturing Co.); AGC CHEMICALS AMERICAS INC.; AGC, INC. (f/k/a Asahi Glass Co., Ltd.); ANGUS INTERNATIONAL SAFETY GROUP, LTD; ARCHROMAMiranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the U.S. Supreme Court in which the Court ruled that the Fifth Amendment to the U.S. ...The companies that staked a flag in the state for the medical program were in a great position to quickly hit the ground running....HRVSF Arizona voters approved the sales of adult use cannabis back in November and by January some providers...Use the following information of Cruz Inc. and answer the questions. CRUZ, INC. Income Statement For Year Ended December 31, 2020 \begin{array}{c} \textbf{CRUZ, INC ... Arizona v mauro, See Arizona v. Mauro, 481 U.S. 520, 527-29 (1987) (holding that officers did not interrogate suspect by allowing him to speak with his wife in the presence of an officer where there was no evidence that officers were attempting to elicit incriminating statements and the suspect could not have felt coerced into incriminating himself); United ..., McLaughlin (1991) | Read | Listen. Sanchez-Llamas v. Oregon (2005) | Read. Snyder v. Phelps (2011) | Read | Listen. Smith v. United States (2013) | Read | Listen. Here are the most important and seminal cases issued by the U.S. Supreme Court pertaining to law enforcement., On March 31, 1980, Ohio State Highway Patrol Trooper C.J. Williams observed Richard McCarty's vehicle weaving back and forth on Interstate Highway 270. He followed the car, pulled McCarty over, and asked him to exit the vehicle. Williams noticed that McCarty had trouble standing, and thus determined that he would charge McCarty with a traffic ..., Tucson, Arizona is a great place to get away and explore the beauty of the desert. Whether you’re looking for a weekend getaway or an extended vacation, there are plenty of options for accommodations., Mauro was convicted of murder and child abuse, and sentenced to death. The Arizona Supreme Court reversed. 149 Ariz. 24, 716 P.2d 393 (1986). It found that by allowing Mauro to speak with his wife in the presence of a police officer, the detectives interrogated Mauro within the meaning of Miranda., Arizona v. Mauro, 481 U.S. 520 (1987) The defendant invoked his right to remain silent after his arrest. Subsequently, the defendant’s wife went to the police station and talked to the defendant in a private room. In the room, however, was a police officer for purposes of safety and a tape recorder which was clearly visible to anyone., Justices Marshall, Brennan, and Stevens dissented, id. at 305, 307. Similarly, the Court found no functional equivalent of interrogation when police allowed a suspect's wife to talk to him in the presence of a police officer who openly tape recorded the conversation. Arizona v. Mauro, 481 U.S. 520 (1987). See also Illinois v., xv table of contents preface.....v about the author.....ix selected federal constitutional provisions.....xi table of cases....., G.R. No. 86042 April 30, 1991 - FEAGLE CONSTRUCTION CORPORATION v. MAURO DORADO, ET AL. : Philipppine Supreme Court Jurisprudence, Turquoise has been a popular gemstone for centuries, and Kingman Arizona Turquoise is one of the most sought-after varieties. The unique blue-green hue of this stone has been used in jewelry and art for thousands of years, and it continues ..., Arizona v. Mauro, 481 U.S. 520, 529 (1987). "There were no accusatory statements or questions posed by law enforcement officials." United States v. De La Luz Gallegos, 738 F.2d 378, 380 (10th Cir. 1984). Officer Gonzales took a direct route from the pickup where the evidence was found, to his patrol car where he intended to secure it., Arizona v. Mauro, 481 U. S. 520, 481 U. S. 526 (1987). In Rhode Island v. Innis, 446 U. S. 291 (1980), the Court defined the phrase "functional equivalent" of express questioning to include "any words or actions on the part of the police (other than those normally attendant to arrest and custody) Page 496 U. S. 601, Explore summarized Criminal Procedure case briefs from Cases on Criminal Procedure - Bloom, 2021 Ed. online today. Looking for more casebooks? Search through dozens of casebooks with Quimbee., Arizona v. Mauro 481 U.S. 520 (1987) FACTS: November 1982, Mauro openly went into a K-Mart store in Arizona and admitted that he had killed his son. Store employees called the police and waited for the Flagstaff Police Department to arrive. When police arrived, Mauro proceeded to lead officers to his son dead body. Mauro was then placed under arrest …, The caller stated that a man had entered the store claiming to have killed his son. When officers reached the store, respondent Mauro freely admitted that he had killed his son. He directed the officers to the child's body, and then was arrested and advised of his constitutional rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966)., The decision was Arizona v. Mauro, No. 85-2121. Food Stamps And Labor Strikers The Court agreed to decide whether the Government may limit a family's eligibility for food stamps when a member of ..., Commonwealth v. Rubio, 27 Mass.App.Ct. 506, 512, 540 N.E.2d 189 (1989), quoting Arizona v. Mauro, supra at 529-530, 107 S.Ct. at 1936-1937. See also Innis, supra at 301, 100 S.Ct. at 1689-1690 (Miranda safeguards are designed to afford a suspect in custody added protection against coercive police practices). 7, Arizona v. Mauro. William Carl Mauro murdered his son in Flagstaff. Upon his arrest, he invoked the Miranda rights recited by officers. Later, his wife asked to be allowed to talk to him, and officers cautioned Mr. and Mrs. Mauro that for security, a police officer would have to be present while they spoke. This officer openly recorded the ..., (Mauro, 2012 References: Facts and case summary - New Jersey v. T.L.O. United States Courts. (n.d.). Retrieved April 23, 2023, from - jersey-v-tlo Facts and case summary - miranda v. Arizona. United States Courts. (n.d.). Retrieved April 23, 2023, from - miranda-v-arizona. End of preview. Want to read all 2 pages? Upload your study docs or ..., IN THE COURT OF APPEALS STATE OF ARIZONA DIVISION ONE ) ) ) ) ) ) ) ) ) In re JOHN M. 1 CA-JV 01-0091 DEPARTMENT B O P I N I O N Filed 12-24-01 Appeal from the Superior Court in Maricopa County Cause No. JV-145099 The Honorable Janet E. Barton, Judge AFFIRMED Richard M. Romley, Maricopa County Attorney By Jeffrey A. Zick, Deputy County Attorney ..., The significance of Arizona v. Mauro is also explained, together with the relevance of Arizona v. Mauro impact on citizens and law enforcement. Citation of Arizona v. Mauro 481 U.S. 520 (1987 . This entry was posted in A and tagged AR, Interrogation for Miranda Purposes on February 14, 2015 by Staci Strobl., See Arizona v. Mauro, 481 U.S. 520, 526-30 (1987) (finding no interrogation or functional equivalent under Miranda or Innis when officers permitted defendant to speak with his wife in their presence and recorded the conversation but did not ask questions about the crime and did not arrange for the wife to elicit incriminating statements); see ..., A comprehensive list of all case law citations in the Constitution Annotated alongside the Constitution Annotated essays in which the citations are located., See Arizona v. Mauro, 481 U.S. 520, 529-30, 107 S. Ct. 1931, 1936-37, 95 L. Ed. 2d 458 (1987). The need to give a Miranda warning arises when: (1) the defendant is in custody; and (2) is interrogated. See United States v. Griffin, 922 F.2d 1343, 1347 (8th Cir. 1990). While the two elements involve separate inquiries, they are also interrelated ..., Study with Quizlet and memorize flashcards containing terms like Miranda v Arizona (1966) Facts, Miranda v Arizona (1966) Precedent, Yarborough v Alvarado (2004) Facts and more., See e.g., Stenehjem v. Sareen (2014) 226 Cal. App. 4th 1405. For instance, the Ralph Civil Rights Act, California Civil Code Section 51.7, which provides a civil remedy for threats or acts of violence based on participation in labor disputes or because of race, gender or other protected characteristics. Fuhrman v., Miranda v. Arizona (1966) answer. Established the famous requirement of a police "rights advisement" of suspects. question. Weeks v. U.S. (1914) answer. ... Mapp v. Ohio (1961) answer. Exclusionary Rule: made exclusionary rule applicable to criminal prosecutions at the state level - harboring fugitive wanted for bombing - arrested for …, Arizona v. Mauro, 481 U.S. 520 (1987) The defendant invoked his right to remain silent after his arrest. Subsequently, the defendant's wife went to the police station and talked to the defendant in a private room. In the room, however, was a police officer for purposes of safety and a tape recorder which was clearly visible to anyone., v. Mauro, 149 Ariz. 24, 716 P.2d 393, 400 (1986) (en banc). 3. Mauro 716 P.2d at 400. In making its determination, the Arizona court looked solely at the intent of the police. Id. The Arizona court compared a suspect's right to silence until he speaks with an attorney under the fifth amendment, U.S. CONST. amend. V, with a suspect's, Mauro was convicted of murder and child abuse, and sentenced to death. The Arizona Supreme Court reversed. 149 Ariz. 24, 716 P.2d 393 (1986). It found that by allowing Mauro to speak with his wife in the presence of a police officer, the detectives interrogated Mauro within the meaning of Miranda. , Compare Arizona v. Mauro, 481 U.S. 520, 527 (107 SC 1931, 95 LE2d 458) (1987). Defendant had retained an attorney but he initiated the discussions with the law enforcement personnel. They only furnished him a willing audience for his story and engaged in no attempt to interrogate him or elicit information from him. Defendant ignored their ..., Ernesto Arturo Miranda was born in 1940 and grew up in Mesa, Arizona. He was called Ernie as a youth but went by Ernest as an adult. He was the fifth son of Manuel A. Miranda, a house painter who had immigrated to the United States from Sonora, Mexico, as a child. Ernie's mother died when he was five years old and his father remarried the ..., (See Arizona v. Mauro (1987) 481 U.S. 520, 529 [95 L.Ed.2d 458, 468, 107 S.Ct. 1931].) In any event, it is apparent that defendant had ample opportunity to explore the issue through his own examination of the police officers, yet he failed to do so. The People's successful hearsay objection certainly did not preclude such alternate methods of ...