Rich, Robert M. (1977). Essays on the Theory and Practice of Criminal Justice. ISBN978-0-8191-0235-5. "The origin of the exception goes back in English history to the Ordinance of 1233 which instituted night-watchmen, and directed them 'to arrest those who enter vills at night and go about armed.' Later the Ordinance of 1252 mentions 'disturbers of our peace.'"