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United States v. Ramsey

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Brief Fact Summary. Customs officials opened, without a warrant, eight envelopes from Thailand and found heroin.

Synopsis of Rule of Law. Letters and envelopes from foreign countries are subject to search under the historical “border exception” to the Fourth Amendment.

Points of Law - Legal Principles in this Case for Law Students.

The seizure of stolen goods is authorized by the common law; and the seizure of goods forfeited for a breach of the revenue laws, or concealed to avoid the duties payable on them, has been authorized by English statutes for at least two centuries past;† and the like seizures have been authorized by our own revenue acts from the commencement of the government.

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Facts. Customs officials were investigating a heroin-by-mail “enterprise” in the Washington, D.C. area. Customs agents opened eight suspicious envelopes from Thailand, discovering heroin. They did not have a warrant to open the envelopes.

Issue. Whether mailed letters are subject to the “border exception.”

Held. No. The court discussed the historical rationale of the border exception. “Border searches . . . 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 was no need for a warrant to open the envelopes.

Discussion. “The ‘border search’ . . . is a longstanding, historically recognized exception to the Fourth Amendment’s general principle that a warrant be obtained.”


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