Law School Case Brief
United States v. Ramsey - 431 U.S. 606, 97 S. Ct. 1972 (1977)
Border searches, from before the adoption of the Fourth Amendment, have been considered to be "reasonable" by the single fact that the person or item in question had entered into our country from outside. There has never been any additional requirement that the reasonableness of a border search depended on the existence of probable cause. This longstanding recognition that searches at our borders without probable cause and without a warrant are nonetheless "reasonable" has a history as old as the Fourth Amendment itself.
At a post office in New York City where incoming international airmail was taken for sorting and customs inspection, a United States customs official observed eight bulky envelopes mailed to addresses in the Washington, D.C., area from Thailand, a country known by the customs officer to be a source of narcotics. After feeling the envelopes and finding that they weighed much more than the normal weight of airmail letters, the official, acting without a warrant, opened the envelopes and discovered that they contained heroin. Subsequently, defendant Charles W. Ramsey and three others, all of whom were found to be connected with some of the heroin, were prosecuted for narcotics offenses in the United States District Court for the District of Columbia. At trial, the court denied defendants' motion to suppress the heroin. Defendants were found guilty, and they appealed. The United States Court of Appeals for the District of Columbia Circuit reversed the convictions, holding that the Fourth Amendment forbade the opening of international mail without probable cause and a search warrant. The United States was granted a writ of certiorari.
Was the custom officer's act of opening the envelopes, without a warrant, violative of the defendants' Fourth Amendment rights?
The Supreme Court of the United States held that the customs official's opening of the letters did not violate the Fourth Amendment, but fell within the border search exception to the requirements of the Fourth Amendment, whereby a search at a United States border was considered reasonable under the Amendment, notwithstanding the absence of probable cause or a warrant. The Court held that 19 U.S.C.S. § 482 expressly authorized searches of the mails entering United States borders, and that such searches were not confined to packages as opposed to letters. The Court held that the § 482 "reasonable cause" standard was less stringent than the Fourth Amendment "probable cause" standard, and was satisfied where the officer, based on experience, became suspicious of a number of similar looking letters originating from Thailand that contained more than letter paper. The Court held that a border search was an exception to the warrant requirement and was not based upon the existence of "exigent circumstances." The Court noted that the Congress that proposed the Bill of Rights also enacted the first customs statute authorizing such searches.
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