Judge Victor Marrero of the Southern District of New York found on 28 September 2004, that NSLs violate the Fourth Amendment ("it has the effect of authorizing coercive searches effectively immune from any judicial process") and First Amendment.
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After having the case returned to his court for reconsideration in light of the revisions made to the USA PATRIOT Act, on September 6, 2007, Judge Victor Marrero struck down the parts of the law that allowed the FBI to compel companies to provide customer records without court authorization and forbade the companies from telling the customers or anyone else what they had done.
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