Confiscation is the taking of private property for public use without compensation. It may occur legally when the government seizes property used in illegal practices. Confiscation may occur without an arrest of a person because it is seen as an arrest of property, rather than a person, and the necessity of finding a party guilty is not required in all cases. In many cases, the guilt or innocence of the property owner is irrelevant and the government need not prove anything "beyond a reasonable doubt". In order to seize property, there must be either a warrant or a showing of probable cause. The mere showing of probable cause to support the forfeiture of an individual's property has been a controversial issue. Court opinion varies, but probable cause most often means that the government need only demonstrate reasonable grounds for the belief that the property is properly subject to forfeiture, which can be supported by something less than prima facie proof, but more than mere suspicion. The Peoria, Illinois noise ordinance (Sections 15-75 and 15-77) allows confiscation of vehicles that emit excessive sound caused by sound producing devices. Colorado Springs, Colorado (Section 9.8.102) permits confiscation of sound producing devices.