Challenging Wiretap Applications as Unconstitutionally Overbroad and Lacking Particularity: The Ill-

State and federal courts authorized 3,194 wiretap applications in 2010; only one application was denied. When law enforcement officers target an organization, the organization must have a structure beyond "loose association of criminals." If the government can claim that loosely associated individuals constitute a criminal organization, there is no limit to the extent and length of time to which the government can proceed in intercepting personal and private information from an infinite number of people. When the organization is not specifically defined, described, and structured, the wiretap application does not satisfy the constitutional and statutory requirements of particularity.