Sunday, December 22, 2013

Doyle v. Ohio case brief (Criminal Procedure)

Doyle v. Ohio case brief summary
462 U.S. 610 (1976)

CASE SYNOPSIS
Petitioner, United States, challenged a judgment of the Court of Appeals for the Fifth Circuit, which reversed respondents' convictions for conspiracy, possession, and importation crimes related to marijuana found by customs officers who, acting under 19 U.S.C.S. § 1581(a), boarded respondents' boat to inspect its documents, without any suspicion of wrongdoing.

CASE FACTS
Petitioner challenged the lower court's reversal of respondents' convictions for conspiracy, possession, and importation crimes related to marijuana found by customs officers who boarded their boat, anchored in a shipping channel with ready access to the open sea, to inspect its documents without any suspicion of wrongdoing, on grounds that the boarding was not reasonable under U.S. Constitutional Amendment IV.

DISCUSSION

  • The court granted certiorari and reversed, holding that the boarding was reasonable and consistent with the Fourth Amendment. 
  • The court cited the historical pedigree of 19 U.S.C.S. § 1581(a), allowing customs officers broad authority to board vessels for inspection of documents, and contrasted the nature of waterborne commerce with vehicular traffic, where random suspicion-less stops were not allowed beyond the border, because of the availability of fixed checkpoints and roadblocks. 
  • The court noted the lack of licensing for boats by which observation of external markings could verify compliance with law, and the government's interest in assuring compliance with documentation requirements, particularly in waters providing ready access to the open sea.

CONCLUSION
The judgment was reversed.

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