THIS NOTE DISCUSSES THE FOURTH AMENDMENT PORTION OF THIS DECISION, GIVING PARTICULAR ATTENTION TO THE COURT'S RELIANCE ON THE 1974 SUPREME COURT DECISION IN PARKER V. LEVY AND ITS TREATMENT OF THE WARRANT REQUIREMENT AND REASONABLENESS ISSUES. IN PARKER V. LEVY, THE COURT HELD THAT THE MILITARY CONTEXT MAY REQUIRE A 'DIFFERENT APPLICATION' OF CERTAIN CONSTITUTIONAL PROTECTIONS DUE TO THE FUNDAMENTAL NECESSITY FOR OBEDIENCE AND IMPOSITION OF DISCIPLINE. THE AUTHOR ARGUES THAT IT IS UNCLEAR WHETHER THE CIRCUIT COURT'S EXTENSION OF THE LEVY DICTUM (WHICH DEALT WITH THE FIRST AMENDMENT) TO FOURTH AMENDEMNT RIGHTS WAS APPROPRIATE OR THAT THE COURT'S REASONING IN SUPPORT OF ITS RECOGNITION OF SO BROAD AN EXCEPTION TO THE WARRANT REQUIREMENT IS CONSISTENT WITH THAT OF THE SUPREME COURT IN ITS PRIOR CASES UPHOLDING WARRANTLESS SEARCHES. HE ALSO POINTS OUT THAT THE COURT'S ARGUMENTS SUPPORTING THE REASONABLENESS OF THE SEARCHES WOULD NOT SUPPORT THE IMPOSITION OF A SIMILAR MASS SEARCH PROGRAM ON CIVILIANS BY CIVILIAN AUTHORITIES. THE POTENTIAL IMPACT OF THIS DECISION IS EXAMINED AND ALTERNATIVE FORMULAE FOR ANALYZING CONFLICTS BETWEEN MILITARY NEEDS AND THE BILL OF RIGHTS ARE IDENTIFIED. SUGGESTED IS A TWO-PRONGED TEST FOR ASSESSING THE CONSTITUTIONAL VALIDITY OF CLAIMS OF MILITARY NECESSITY - A STRONG SHOWING THAT AN IMPORTANT MILITARY INTEREST IS AT STAKE AND THAT THERE IS A COMPELLING NEED TO TAKE OTHERWISE UNCONSTITUTIONAL ACTION TO PROTECT THAT INTEREST.