United States v. Lee - Impact

The Court's ruling in this case and in Maul v. United States, legalized expansion of the U.S. Coast Guard's jurisdiction to enforce the Tariff Act and the National Prohibition Act beyond the territorial waters and the high seas 12 miles outward from the coast. The ruling reflected the government's efforts to intensify the pressure against "rum-runners" who circumvented the prohibition laws by smuggling liquor into and out of the United States. Despite the broad powers given the government, prohibition was ultimately unsuccessful. In 1933, ratification of the Twenty-first Amendment repealed the Eighteenth Amendment and rendered the National Prohibition Act inoperative. Other courts subsequently agreed that the use of artificial means to illuminate a darkened area does not constitute a search under the Fourth Amendment. The ruling has also been used to support the proposition that an arresting officer may look around at the time of the arrest and seize evidence of crime or contraband articles that are in plain sight and in his immediate and discernible presence. This proposition is the basis for what is commonly known as the "plain view" exception to the general requirement of a valid search warrant to legitimize a search or seizure.