In examinging Fourth Amendment searches and seizures, this Article makes a distinction between the concepts of "consent" and "voluntariness." The former need not entail the latter, suggests the piece, since "consent" is nothing more than a label placed on a given police/suspect interaction in order to legitimate that interaction. Professor Williams, an accomplished attorney whose clients include Mumia Abu-Jamal, wrote this piece specifically for the Indiana Law Journal, in response to Professor Ric Simmons's article Not "Voluntary" But Still Reasonable: A New Paradigm for Understanding the Consent Search Doctrine, published in Voume 80 of the Journal.