The SCOTUS has reaffirmed that the US police can stop anyone and do a personal body search based on a suspicion of a concealed weapon. | SCOTUS Up the Wazoo – Cartoon by Pat Bagley on Apr 3, 2012
Overwhelming data point towards the fact the US is a police State beyond comparison.
In 2011, New York police stopped about 700,000 people on the road – and nearly half of these people were intrusively searched. One estimate put the total number of such searches in New York alone at 4 million – 40 lakhs, in the past decade.
All this in a city of eight million – a little larger than Pune. Imagine 2000 body searches every single day in Pune.
These personal body searches and CCTV surveillance has become common across the US | Cartoon titled Travel School and Prison By Andy Singer, on 11/20/2006
Police procedures demands that a the crotch is manually felt by hands – and in case of women, even the area between breasts.
Remember these figures are for New York only. National figures will be higher.
The New York City Police Department under its increasingly unpopular stop-and-frisk program (revealed) New Yorkers were stopped nearly 700,000 times last year.
Judge Shira Scheindlin of Federal District Court granted class action status to a lawsuit accusing the Police Department of using race as the basis for stopping and frisking New Yorkers. The judge rebuked the city for its “deeply troubling apathy toward New Yorkers’ most fundamental constitutional rights,” and found “overwhelming evidence” that the program had led to thousands of baseless, unlawful stops. Despite the police claims that the stops keep criminals and weapons off the streets, only about 6 percent of stops lead to arrests, and last year, only one in every 879 stops turned up a gun.
According to the department, it conducted 203,500 stops in January, February and March of this year — a record number — but stopped only 133,934 in April, May and June.
A young woman from Harlem Heights said police officers who claimed to be searching for a rapist interrupted her and two female friends, demanded identification and then patted her down. “It was uncalled-for,” she said. “It made no sense. How are you going to stop three females when you are supposedly looking for a male rapist?”
via Stop-and-Frisk in New York City – NYTimes.com.
Not surprisingly 85% of these target were African-Americans and Hispanics.
Steve Kohut, born and raised in Manhattan’s Lower East Side, says he’s been stopped and frisked “more times than I can remember” since he was 12. “It was just life to me,” Kohut said.
He only realized that it was not common to all areas of the city when he visited a friend’s upscale neighborhood. It prompted him to question the practice. “Wait a minute, the cops don’t stop you every time you go to the store over here? They don’t do that to you? They don’t search you? They don’t push you up against a wall? They don’t put your face on the hood of their car?”
“It’s not a positive thing to just declare martial law on a colored community or a poor community, which is pretty much what they’re doing.”
via NYPD’s stop-and-frisk policy to be reviewed by US department of justice | World news | guardian.co.uk.
In some areas, it has become reflex action for people to prepare themselves for a search – as soon as they see a policeman in uniform.
In her lower Manhattan office, Donna Lieberman, the executive director of the New York Civil Liberties Union, raises her hands in surrender.
Lieberman, 63, is miming the resigned reaction of young black and Latino men who she says are stopped and frisked so often by the New York Police Department that they put their hands in the air as soon as they see an officer approaching.
“The police don’t say a thing,” says Lieberman of the technique, which the NYPD says has netted 800 guns in a 10-year period. “They just go right for the pockets.”
via New York, Philadelphia police stops draw criticism – thestar.com.
What’s on the menu? You got choice. A Police State or a Military State | by Tim Kelly at Monday, January 11, 2010
Is New York the only city where the police have gone berserk?
In Philadelphia, a court challenge to stop-and-frisk resulted in an agreement involving the mayor, the police commissioner and those who brought the suit, to make the force more accountable. Officers, who once recorded stop and frisk details on paper, now use mini laptops and that information goes into an electronic data base that can be monitored by Messing and the ACLU.In 2009, 250,000 people were stopped, principally black and Latino men, in a city of 1.5 million.
via New York, Philadelphia police stops draw criticism – thestar.com.
Unlike popular image, for years the legal, civil rights community and the media simply watched. The challenge to these abusive police searches mounted only after overwhelming evidence was built up.
In recent years, stop-and-frisk tactics employed by police departments in other major cities have been impugned by civil rights leaders. In 2010, the American Civil Liberties Union of Pennsylvania filed a class-action federal lawsuit against the Philadelphia Police Department. The lawsuit led to a settlement in which Philadelphia officials agreed to adopt safeguards to make sure police stops were conducted legally, and to accept oversight by an independent monitor. After the changes, the number of street stops declined.
via Number of New York Police Street Stops Falls 34 Percent – NYTimes.com.
TSA seems to be getting away with the most intrusive body search by any agency in the world | Future Travel by Cameron Cardow editorial; cartoonist for the Ottawa Citizen; Dec 14 2010.
These intrusive search procedures increased even as crime figures remained high.
the explosion in stop-and-frisks under Bloomberg’s administration – by 600% in the last decade – has had little impact on the number of people of shot in New York City, in contrast to claims made by the mayor and the commissioner that the practice is making the city safer. NYPD statistics reveal that 1,821 people were victims of gunfire in 2011, a figure which is almost identical to the 1,892 people who were shot in 2002 when Bloomberg came into office.
via NYPD’s stop-and-frisk policy to be reviewed by US department of justice | World news | guardian.co.uk.
Outrage followed and the complete lack of logic was revealed, as data of searches on the female-persons was revealed.
Last year, New York City police officers stopped 46,784 women, frisking nearly 16,000. Guns were found in 59 cases, according to an analysis of police statistics by The New York Times.
While the number of women stopped by officers in 2011 represented 6.9 percent of all police stops, the rate of guns found on both men and women was equally low, 0.12 percent and 0.13 percent, respectively. Civil rights leaders have argued that the low gun-recovery rates are a strong indication that the bulk of stop-and-frisk encounters are legally unjustified. (The number of police stops has dropped by more than 34 percent in recent months.)
When officers conduct stops upon shaky or baseless legal foundations, people of both sexes often say they felt violated. Yet stops of women by male officers can often involve an additional element of embarrassment and perhaps sexual intimidation, according to women who provided their accounts of being stopped by the police. And many incorrectly believe that the police, like Transportation Security Administration officers, are required to have female officers frisk women.
That search is not random; it is based on information provided to an officer, like a detailed description of an armed suspect, or actions that raise an officer’s reasonable suspicion that the woman may be armed, she added.
And although the police stops of women yielded very few guns, they did produce 3,993 arrests last year.
Crystal Pope, 22, said she and two female friends were frisked by male officers last year in Harlem Heights.
Besides, Ms. Pope said, she thought male officers were required to summon a female colleague when conducting a frisk.
That belief, though incorrect, is shared by many women, said Andrea Ritchie, a civil rights lawyer and co-coordinator of Streetwise and Safe, a nonprofit organization that focuses on police practices that affect young lesbian, gay, bisexual and transgender people who are also members of ethnic minorities.
via In Police Pat-Downs, Many Women See Sexual Overtones – NYTimes.com.
A brilliant PR coup to damp simmering public rage at these pat-downs, the TSA (in collusion, or otherwise) ensured media coverage of a pat-down done on Henry Kissinger.
TSA screeners at New York’s LaGuardia Airport gave former Secretary of State Henry Kissinger a pat-down. The 88-year-old Nobel Peace Prize winner was in a wheel chair because of the long walk to the gate when he was pulled aside for screening.
Witnesses were shocked at the sight of him being patted down, and said it looked like the agents had no idea who Kissinger was.
via Former Secretary of State Henry Kissinger Given Pat-Down by TSA | Fox News Insider.
In recent months, several officers said, many sergeants conducting roll calls have stopped emphasizing the need to stop and question people on the street.
“They don’t ask for it anymore,” an officer in the Bronx said. “They just stopped.”
This is key, the officer said, because when sergeants were asking for them, “it starts becoming a quota or a production goal.”
“Why is it so important how many 250s someone did?” the officer added, referring to a form, a UF-250, filled out after a stop-and-frisk episode.
After the first quarter of 2012, police and city officials began to wonder how high the number would go in future years, and some privately questioned why the number of street stops continued to rise even as crime levels remained relatively flat in recent years.
via Number of New York Police Street Stops Falls 34 Percent – NYTimes.com.
In police parlance, this is called a Terry search. The SCOTUS decided in this case that as long as a policemen believed that a person
- Had committed
- Was going to commit a crime
- Probably armed
the police had a right to search.
One more minute, and it becomes clear that anyone can be searched under these three qualifications.
The constitutional origin and basis for police protective searches stems from the U.S. Supreme Court case of Terry v. Ohio (392 U.S. 1 (1968). In the Terry case, the high court first considered the issue of whether police pat downs were constitutional. That case evaluated the police practice of weapon searches on accosted persons and deemed it governed by the U.S. Constitution’s Fourth Amendment protections.
The decision stood for the proposition that police protective searches were legitimate and constitutional, as it established justifications for the searches in the jurisprudence. Specifically, the supreme court held in Terry that the Fourth Amendment’s bar on unreasonable searches and seizures is not violated by the police when they stop a suspect and pat down that suspect without probable cause to arrest him or her, so long as the police have a reasonable suspicion that the suspect committed, is committing, or committed an offense, and the officer has a reasonable belief that the suspect might be dangerously armed.
via What Is Permissible During a Police Pat Down? – Attorneys.com.
With one law-breaker or law enforcer, for every 17 adult males, the US is a world leader. For the 70 million American males in the 18-60 years of age who are the predominant target; there are 17 apex American secret service agencies that track these 70 million people. The biggest secret service in the world, the largest prisoner population, in addition to one of the the largest police forces in the world, make US clearly a leader of the ‘Free’ World.
those opposed to the Transportation Security Administration’s (TSA) new ‘enhanced’ pat down searches is that these pat downs violate a traveler’s Fourth Amendment rights.the Fourth Amendment to the United States Constitution it reads “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”While the new TSA enhanced pat downs may violate the Fourth Amendment on the surface,
the 9th Circuit Court of the United States ruled on the search of passengers in airports back in 1973, which effectively suspends limited aspects of the Fourth Amendment while undergoing airport security screening.
In 1973 the 9th Circuit Court rules on U.S. vs Davis, 482 F.2d 893, 908, there are key pieces of wording that give the TSA its power to search essentially any way they choose to. The key wording in this ruling includes “noting that airport screenings are considered to be administrative searches because they are conducted as part of a general regulatory scheme, where the essential administrative purpose is to prevent the carrying of weapons or explosives aboard aircraft.”
U.S. vs Davis goes onto to state “[an administrative search is allowed if] no more intrusive or intensive than necessary, in light of current technology, to detect weapons or explosives, confined in good faith to that purpose, and passengers may avoid the search by electing not to fly.”
U.S. vs Davis was upheld by the 9th Circuit Court in 1986 in U.S. vs Pulido-Baquerizo, 800 F.2d 899, 901 with this ruling “To judge reasonableness, it is necessary to balance the right to be free of intrusion with society’s interest in safe air travel.”
These 9th Circuit Court ruling laid the path for the creation of Public Law 107-71, the Aviation Transportation and Security Act, which was virtually unopposed by legislators when it was it was signed into law on the 19th of November 2001 by President George W. Bush. This law laid the groundwork for the Transportation Security Administration and the evolution of its current security procedures.
These laws give the Department of Homeland Security (DHS) and Transportation Security Administration significant legal latitude to perform the searches utilizing their current procedures without fear of violating the Fourth Amendment.
via How The TSA Legally Circumvents The Fourth Amendment – Flying With Fish.
Simmering discontent about the intrusion is now out on the streets too | Pre-Flight Check. Friday, November 26th, 2010 by Ted Rall. at cartoonistswithattitude.org
The Terry pat-down industry in the US Police got a big boost when the Supreme Court of the United States (SCOTUS) upheld the police case against Lemon Montrea Johnson (argued December 9, 2008–Decided January 26, 2009) that police did indeed have the power to stop and search for weapons – and any other item which discovered during this search could be grounds for prosecution.
The U.S. Supreme Court decided today that, based on an Arizona case, cops who pull vehicles over in traffic stops can pat down passengers for weapons without any suspicion of wrongdoing.
We suspect this ruling could make it easier for unscrupulous police officers to abuse typical search standards.
Anytime an officer is suspicious someone is carrying drugs or other illegal contraband, the person can be searched for “weapons.” The officer has nothing to lose, now that the Supreme Court has spoken: If the search produces no weapons, there’s no legal foul ball. But if it produces drugs, the cop is rewarded with a felony bust.
via Pat-Downs of Passengers by Police Approved by U.S. Supreme Court – Phoenix News – Valley Fever.
A few cases have been overturned – but these precedents have not been enough, in number or strength of juridical importance, to turn the tide.
The Court of Appeals recently reaffirmed the long standing rule that an officer who conducts a traffic stop must have a particularized suspicion that an occupant of the vehicle poses a safety threat before the occupant can be patted-down. The Court went on to hold that this rule holds true even if the officer intends to search the vehicle.
In Molina v. State, a Gwinnett County case, an officer conducted a traffic stop of a pickup truck after noticing a broken tail light. Upon being asked by the officer, the driver consented to a search of the truck. The driver and the passenger, Molina, were then asked to step out of the truck. A backup officer conducted a “Terry pat-down” of Molina to search for weapons. During the pat-down, the officer felt “a large brick-like substance or material or object in his front waistband.” Unsure as to whether the brick was a weapon or drugs, the officer pulled the brick out and discovered that it was a kilo of cocaine. Molina was then charged for trafficking in cocaine.
At the suppression hearing, the officer testified on direct that prior to the pat-down Molina was breathing heavily and that the artery in his neck was pounding rapidly. The officer also stated: “Other than that. . . [he] was pretty normal.” On cross, the officer stated that he patted-down Molina immediately after he exited the truck. The officer also stated, “Every time we have a consent to search and we get someone out of a vehicle, I always pat them down for weapons.” The officer explained: “While I’m going to be tucked inside somebody’s car I want to know if while they’re standing out there they’re armed.” Molina lost the suppression hearing, and following a bench trial, he was sentenced to the minimum 25 years in prison and a $1 million fine.
On appeal, the Court of Appeals reasoned that, “If the officer has a particularized basis for his suspicion the defendant might be armed or dangerous, he may frisk a suspect.” Quoting Terry v. Ohio, the Court went on to state that, “the issue is whether a reasonably prudent man in the circumstances would be warranted in the belief that his safety or that of others was in danger.”
via Georgia appeals court limits “pat-down” searches and “safety frisks” | Georgia Criminal Defense Lawyers.
The state Supreme Court has thrown out the 2005 methamphetamine conviction of an Olympia man, ruling that police had no right to frisk him just because he was apparently intoxicated and acting nervous in a public building.
The unanimous court overturned a decision by a Thurston County judge and the state Court of Appeals, both of which had found Lt. Don Stevens of the Tumwater Police Department justified in patting down Michael Setterstrom for weapons.
Bystanders had called police the morning of Feb. 28, 2005, to complain that Setterstrom appeared intoxicated.
The court’s ruling means that evidence seized because of that search — including a baggie of methamphetamines — is inadmissible. Setterstrom, who served six months in jail for the conviction, will have the conviction reversed.
According to the court opinion, Setterstrom lied to Stevens about his name, was fidgety and seemed nervous.
Even though Setters actually do or say anything threatening, Stevens frisked him. While he felt hard objects in the man’s front pocket, he testified “that none felt like a gun.”
Among the items the officer pulled from the pocket was a small baggie containing white powder. Stevens placed it all on the bench and told Setterstrom he was under arrest.
“What happened next was, we assume, unusual,” wrote Justice James R. Johnson for the court. “Setterstrom dropped to his knees, grabbed the baggie, and swallowed it.”
Efforts to make Setterstrom spit it out were not successful, and Johnson wryly noted that, “For obvious reasons, police never recovered the baggie.”
Based on these actions, Setterstrom was arrested and Stevens obtained a search warrant for his backpack, where officers found a small safe containing a baggie of methamphetamine, a syringe, a pipe and a set of scales. In Thursday’s ruling, the justices said that because the original pat-down was illegal, so was the search warrant that resulted from it.
while officers have every right to protect themselves, they must have a reason to suspect someone may be armed and dangerous.
“Officers must have some basis beyond nervousness and lying to justify the intrusion of a frisk,” the opinion said. “The officer here lacked such a basis.”
via Local News | Court: Police pat-down was not justified | Seattle Times Newspaper.
In JOHNSON v. THE STATE, (A11A0941.), Judge McFadden, dissenting wrote
Officer Spahr lacked authority to conduct the pat-down; and Johnson’s consent to the subsequent search that turned up the drugs was not freely and voluntarily given, but rather was tainted by the illegal pat-down. Therefore, the trial court should have granted Johnson’s motion to suppress, and I would reverse his conviction.I now turn to the question whether Officer Spahr had constitutionally adequate grounds to conduct the pat-down search. I would find that the state did not meet its burden of establishing that Spahr reasonably suspected that Johnson was armed and dangerous or otherwise a threat to his personal safety. So Spahr did not have constitutionally adequate grounds for the pat-down.Before an officer places a hand on the person of a citizen in search of anything, he must have constitutionally adequate, reasonable grounds for doing so. If an officer conducts a pat-down for weapons without sufficient justification, any evidence discovered is inadmissible under the exclusionary rule. Constitutionally adequate, reasonable grounds for a pat-down for weapons for officer or bystander safety are present when, based on particular and articulable facts, the officer actually and reasonably suspects that the individual is armed and dangerous or is otherwise a threat to personal safety.The state has the burden of proving that the pat-down was lawful. Molina, 304 Ga.App. at 95. That burden entails proving that the officer reasonably believed the suspect to have been “armed or otherwise dangerous.” No right is held more sacred, or is more carefully guarded, by the common law, than the right of every individual to the possession and control of his own person, free from all restraint or interference of others, unless by clear and unquestionable authority of law.Since the pat-down was illegal, the relevant question becomes whether Johnson’s consent to the subsequent search that turned up the drugs was voluntarily given and not the product of the illegal pat-down. Johnson argues that he did not freely and voluntarily give his consent because he was surrounded by three officers, one of whom had already conducted the illegal pat-down, and he was not told that he could leave. In other words, Johnson contends that the encounter had not de-escalated into a first-tier encounter, and therefore his consent was not voluntary. To determine whether the encounter became consensual, the courts must look to the totality of the circumstances in determining whether a reasonable person would have felt free to leave.
via JOHNSON v. THE STATE, A11A0941., December 01, 2011 – GA Court of Appeals | FindLaw.
Anything left out …
There are some other developing ‘stories’, which are equally a cause for worry spread over the USA.
County officials are looking into an almost 70% spike in fatal officer-involved shootings in Los Angeles County last year but said it’s too early to tell what, if anything, drove the jump.
Fifty-four people were fatally shot by authorities in 2011, according to autopsy reports analyzed by The Times, an increase all the more notable because it occurred at a time when the number of homicides in the area fell to historic lows. With 612 people killed in the county last year, nearly 1 in every 10 such deaths occurred at the hands of law enforcement officers.
via L.A. County officials looking into spike in fatal police shootings – latimes.com.
In US capital, Washington, DC, an anti-prostitution law is being watched with interest by the rest of USA.
In areas designated as prostitution-free zones, police can make arrests for up to 24 consecutive days if two or more people congregate in public in certain neighborhoods and ignore dispersal orders.
In his testimony, Newsham told council members that the city’s well-publicized prostitution-free zones appear to have played only a minor role in an overall reduction of prostitution in the city. Despite common perceptions, Newsham said, police have never made an arrest using the prostitution-free zone statute.
“While PFZs may have contributed to a temporary displacement of street-level prostitution, development and changing trends in prostitution have likely played a greater role,” Newsham said, noting that there has been a steep decline in prostitution-related calls in the District.
Courts upheld a person’s right to loiter so long as it’s not “being done with the specific intent to commit an illegal act.” Under current law, Gorman said, police do not need “probable cause” to arrest someone using the prostitution-free zone statue.
“It’s about disrupting,” Mendelson said. “If the market has to move because of a prostitution-free zone, it’s going to hurt business.”
via D.C. ‘prostitution-free zones’ probably unconstitutional, attorney general’s office says – The Washington Post.
So how do police identify prostitutes?
Over 1,200 people have signed a petition to demand the right to carry three condoms in the District of Columbia without fear of arrest. Why do 1,200 people think that carrying more than two condoms is against the law?
Widespread media reports of a “three-condom rule” in D.C. began with an item on RH Reality Check investigating the District’s anti-prostitution provisions. The item, written by researchers Aziza Ahmed and Brook Kelly, claimed that in the District of Columbia, “Anecdotal evidence suggests that having three or more condoms is considered a proxy for being a sex worker.”
Last week, the three-condom rule hit Jezebel, where it received 4,426 page-views—and inspired dozens of comments from women concerned that a late-night prophylactic run could send them behind bars. “Don’t many brands sell in 3-packs? Anyone who carries around a new package is automatically carrying 3,” one wrote. “so people in long term relationships that decide to stock up are really screwed,” wrote another. Feministing also picked up the three-condom rule. On Amplify, Jaclyn Friedman worried that her new “cute red vinyl condom case” designed to hold three Trojans could be grounds for arrest. “I once used over a dozen [condoms] in a particularly memorable weekend,” Friedman writes. “And I still wasn’t a sex worker.” Meanwhile, Dibranco’s post has been viewed over 40,000 times.
Where did this “three-condom rule” originate?
It’s not a legal standard. In D.C., police can set up temporary “Prostitution Free Zones” where officers who suspect you of loitering with the intent to commit prostitution can force you to leave the area. If you don’t leave, they can arrest you. The zone can remain in place for up to 10 days. According to the Prostitution Free Zone Law, “prostitution-related offenses” include “repeatedly beckoning to, stopping, attempting to stop, or attempting to engage passers-by in conversation for the purpose of prostitution,” “stopping or attempting to stop motor vehicles for the purpose of prostitution,” or “repeatedly interfering with the free passage of other persons for the purpose of prostitution.” Cops can also ask you to disperse if they recognize you from previous incidents as a gang member or a sex worker, or if a “reliable source” informs the police that they have observed you engaging in prostitution. The law contains plenty of objectionable procedures—they can make me leave my neighborhood if someone “reliable” tells them I’m a sex worker?—but no mention of contraceptives.
According to D.C. police spokesperson Gwendolyn Crump, carrying condoms can lead an officer to suspect prostitution—but there’s no three-condom arrest rule. “Although the possession of multiple condoms may be a factor that leads an officer to suspect (reasonable suspicion) that a person is engaged in prostitution, it is not enough to establish probable cause for any crime,” Crump writes. “Depending on the circumstances, factors such as this may justify an investigative stop—but not an arrest.”
Of course, it’s possible that some D.C. police officers don’t always follow the letter of the law. Is there any evidence that D.C. police have an internal three-condom rule?
According to the report, 8.6 percent of sex workers interviewed claimed that officers had taken “safe sex supplies” from them during their interactions with police; the report also cites evidence of police officers seizing or destroying condoms in Las Vegas and San Francisco. Again, the report’s findings reveal police conduct that can be extraordinarily harmful for D.C.’s sex workers. However, the report includes no magic number of condoms required to ignite suspicion—and it doesn’t provide any evidence that condoms alone are enough to get you locked up.
via Can Having Three Condoms In D.C. Really Get You Arrested? – The Sexist.
For a short while it did appear that the this Prostitution-Free Zone practice was effective. There seemed to be a reduction in prostitution.
The prostitution landscape in the nation’s capital is changing.
WAMU-FM’s “Metro Connection” reported on the District of Columbia’s crackdown on prostitution and why it is that prostitution is moving from areas downtown into residential neighborhoods, especially in Ward 7 east of the Anacostia River.
The migration mostly has to do with a 2006 law that allows chief of the Metropolitan Police Department to temporarily designate some areas of the city as “prostitution-free zones.” In such areas, it is “unlawful for a group of two or more persons to congregate in a public space or property in that area for the purpose of engaging in prostitution or prostitution-related offenses.”
Contrary to public opinion, the carrying of more than two condoms is not itself enough to get a person arrested for prostitution though the City Paper’s former sex columnist Amanda Hess did find that carrying multiple condoms in a prostitution-free zone can lead an officer to suspect that a person is a sex worker — which, in a prostitute-free zone, is enough for the police to tell the person to disperse.
Most of the PFZs so far have been downtown, which has pushed prostitution into other parts of the nation’s capital. WAMU reports that in Ward 2, the downtown jurisdiction traditionally known as D.C.’s prostitution hub, arrests have gone down by 10 percent in the past 10 years. But east of the Anacostia River, arrests have tripled in Ward 7.
The group told WAMU it isn’t seeing any overall decrease in the number of prostitutes working in D.C., though — it’s the same number of prostitutes, just working in different places– More dangerous places, say sex worker advocates.
via D.C. Prostitution Moves East Of Anacostia River.