In 2009, Roger Roots presented evidence that the idea of exclusion can be found in the earliest set of law books published in American history. In 2014, Roots elaborated that certain eighteenth-century British law books and pamphlets which discuss the exclusion of illegally seized evidence circulated widely in the American colonies and were owned by numerous prominent Framing-era lawyers and statesmen. Also in 2014, Professor Richard Re proposed that the Due Process Clause provides an ample basis for the Exclusionary Rule.