This created the “criminalblackman” which would inevitably be the primary target of law enforcement. Alexander argues that implicit and explicit bias contributed to racial disparities in law enforcement, much of the racial bias would occur unconsciously and automatically. “When the time came for the Supreme Court to devise legal rules that would govern the War on Drugs, the court adopted rules that would maximize-not minimize- the amount of racial discrimination that would likely occur” (Alexander 108). The Supreme Court Justices probably had some unconscious bias that affected their