THE ARGUMENTS PRESENTED IN CASES PROHIBITING SUB-FACIAL ATTACKS AT SUPPRESSION HEARINGS ARE ANALYZED AS WELL AS ARGUMENTS PRESENTED TO AND CONSTRUCTED BY COURTS USING A FOURTH AMENDMENT RATIONALE TO ALLOW SUB-FACIAL ATTACKS. A FOURTH AMENDMENT RATIONALE PERMITTING SUB-FACIAL ATTACKS EMPHASIZING THE FUNCTION, IMPORTANCE, AND IMPLEMENTATION OF PROBABLE CAUSE AND PARTICULARITY REQUIREMENTS IS PROPOSED AND OUTLINED. THE AUTHOR CONCLUDES THAT SUB-FACIAL ATTACK SHOULD BE PERMITTED WITHOUT RESTRICTION AND THAT THE PROHIBITION OF THEM REDUCES THE FOURTH AMENDMENT TO A FORM OF WORDS.