Last month Scheindlin lifted an order [JURIST report] that previously required the NYPD to stop using its "stop-and-frisk" practice. There, the judge reasoned that complying with the former order would place an undue burden on the NYPD to train thousands of officers and their supervisors. Two weeks prior Scheindlin declared the "stop-and-frisk" policy unconstitutional [JURIST report] on grounds that it violates the protection against unreasonable search and seizures of the Fourth Amendment [text; Cornell LII backgrounder]. There, she reasoned that officers were not first meeting their requirement of developing a reasonable suspicion to stop and frisk supposed trespassers. Scheindlin's original decision was the first federal ruling to find that the "stop-and-frisk" practice is unconstitutional, though the NYPD has recently received a great deal of scrutiny for various allegations of misconduct. In July, a report issued by a coalition of legal rights organizations said that the NYPD used excessive force and violated the rights of protesters [JURIST report] who participated in the Occupy Wall Street movement in New York City. A month prior, a Muslim rights group filed a lawsuit [JURIST report] in New Jersey seeking to end the department's controversial surveillance program, which allegedly targets individuals based on religious affiliation. In May, following an investigation into the NYPD's surveillance program, New Jersey Attorney General Jeffrey Chiesa concluded that it did not violate the Constitution. In March, NYPD commissioner Raymond Kelly fervently denied [speech; press release] that the surveillance programs were unconstitutional.