Rochin v. California

The Court's decision that the Fourteenth Amendment's guarantee of due process of law prohibits any "conduct that shocks the conscience" by the government established a standard for judging the constitutionality of police tactics for obtaining evidence. However, the Court's justification for its decision faced criticism from legal scholars and from other justices, including Justice Black, who concurred with the decision. Critics argued that standards such as "shocking to the conscience" were too vague and lacked real content.