Divisiveness characterized the Supreme Courts' 1989-1990 term after Justice Brennan's resignation in 1990. Of the 129 signed majority opinions, only 30 percent were unanimous, and 28 percent were by 5-to-4 majority votes. In the fourth amendment area, decisions manifested a contraction of protection in the search and seizure field such as authorization of protective sweeps, rejection of inadvertency element of the plain view rule, and the standard of reasonableness. Important doctrinal statements were declared with the approval of the use of sobriety checkpoints in some circumstances and with the rejection of the extraterritorial reach of the fourth amendment in cases involving nonresident aliens. The Court kept first amendment protections intact in some settings, but expanded powers of legislative bodies regarding control of private possession of child pornography and penalized those using controlled substances as part of religious ceremonies. Confrontation clause issues were handled in a similar 'win some, lose some' manner. Only in the area of protections by the double jeopardy clause did the accused receive expanded benefits. 852 notes