Under search and seizure, State v. Davis established that the Oregon equivalent of the fourth amendment applies extraterritorially to police officers employed by another State. In Commonwealth v. Blouse, Pennsylvania upheld roadblock stops. Regarding the right against self- incrimination, the Tennessee Supreme Court established broader rights for defendants in State v. Smith than was done in Oregon v. Elstad, where the "poisoned tree" doctrine was not applied in a Miranda situation. Regarding the right to counsel, The New Jersey Supreme Court, in State v. Sanchez, established a broader State constitutional right to counsel for postindictment interrogations than exists under the sixth amendment. Under the double jeopardy prohibition, the Colorado Supreme Court, in People v. Serravo, prohibited a retrial after an attempted murder defendant was adjudged not guilty by reason of insanity. A case decided by the Arizona Supreme Court broadly defined the word "victim" as it is used in the State victims' rights provision. The court rejected contentions that someone who might be a suspect could not be a victim. Only someone actually "charged with or held" for an offense can be denied victim status. 37 footnotes