United States v. Lee
The ruling resolved the question of whether the U.S. Coast Guard could board and search American vessels on the high seas and arrest persons on the vessels for violations of the Tariff Act of 1922 and the National Prohibition Act. The Court concluded that if probable cause existed to believe that the vessel and persons in it were violating U.S. revenue laws, the Coast Guard could seize, board, and search the vessel beyond the U.S. territorial waters and the high seas 12 miles outward from the coast. The case was also significant for its ruling that the Coast Guard's use of a searchlight to view the contents of the vessel on the high seas did not constitute a search and thus did not warrant Fourth Amendment protections. The ruling allowed the U.S government to intensify its effort to enforce prohibition by preventing the smuggling of liquor.
In the early twentieth century, individual states and the U.S. government made numerous attempts to control the sale and consumption of alcoholic beverages by its citizens. The most ambitious and well-known attempt was the passage in 1919 of the Eighteenth Amendment, establishing nationwide prohibition. The Eighteenth Amendment prohibited the manufacture, sale, transportation, importation, and exportation of intoxicating liquors for beverage purposes and authorized both Congress and the states to enact enforcing legislation. Congress subsequently passed the National Prohibition Act to prevent the use of intoxicating liquor as a beverage. The act made it unlawful to have or possess any liquor intended for beverage use and provided that a person possessing such liquor had no property rights to the liquor. The act also authorized issuance of search warrants under which such liquor could be seized and destroyed. A subsequent amendment to the act, the Stanley Amendment, allowed warrantless searches of automobiles or vehicles of transportation, as opposed to private dwellings, if the search was not malicious or without probable cause. The passage of the Eighteenth Amendment and the National Prohibition Act did not, however, stop commerce in liquor, but simply drove it underground.
In 1925, the U.S. Coast Guard seized, boarded, and searched a motorboat 24 miles off the coast of Massachusetts, and after finding cans of alcohol on the boat, arrested the persons on board for violation of the Tariff Act and the National Prohibition Act. Two of those arrested were convicted. One of the convicted respondents sued via a writ of error complaining that the seizure, boarding, and search of the motorboat on the high seas violated the Fourth Amendment, and, consequently, that the evidence found during the search--including the liquor--could not be used to convict him. The circuit court of appeals, with one judge dissenting, agreed with the respondents and vacated or cancelled the conviction. The circuit court held that the Coast Guard was not authorized to visit, search, and seize an American vessel on the high seas more than 12 miles from the coast. The circuit court also held that the failure of the government to ratify the seizure by instituting legal forfeiture proceedings against the boat and liquor rendered the seizure illegal, barring use in evidence of any knowledge gained as a result of the search. The United States petitioned for a writ of certiorari seeking review by the U.S. Supreme Court, which the Supreme Court granted.
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