Since the terrorist attacks of September 11, 2001, many state, local, and tribal law enforcement agencies have reestablished and reengineered their intelligence capacity largely through guidance provided by the National Criminal Intelligence Sharing Plan, the Law Enforcement Intelligence Unit file guidelines, and various intelligence training programs developed under the sponsorship of the Bureau of Justice Assistance1 and the Department of Homeland Security Office of Grants and Training.2 While all of these intelligence programs include instruction on the constitutional guidelines regarding civil rights protections, new challenges are emerging that pose renewed concerns about past abuses.