But he also thought that things had changed since he was a district attorney. The professional criminal of the Prohibition and Depression era knew what he was doing and took his chances. The average criminal of the 1950s and 1960s, though, might have turned to crime because of disadvantages or because of degradation (Warren, 1977). The criminal procedure cases coming before the Warren Court involved, from Warren’s point of view, principles of fairness and equality that were all part of the Constitution. It was cases like Irvine v. California, which came up before the Court early in Warren’s first year, that began to shape his thinking and activism. In this case, police officers secretly entered Irvin’s house and planted a hidden microphone
