In Zurcher v. Stanford Daily, 436 U.S. 547 (1978), university students and staff members argued the Fourth Amendment prevented a state from issuing a search warrant for the student newspaper's premises for negatives, films, and pictures revealing the identities of demonstrators who assaulted police officers. 436 U.S. at 550-51. Plaintiffs alleged the warrant was deficient because it authorized the search of a third party's premises, but there was no probable cause to believe that the owners or the possessors of the premises were implicated in a crime that had occurred or was occurring. Id. at 552-53. The Supreme Court held that in the context of a third party search when there is probable cause to believe the fruits or instrumentalities of a crime are in a specific location, the Fourth Amendment does not require that the occupant, owner or possessor of the premises must also be reasonably suspected of crime and be subject to arrest before a search warrant may issue. Id. at 559.