Sunday, November 3, 2013

United States v. Ramsay case brief

United States v. Ramsay case brief summary
431 U.S. 606 (1977)

Petitioner United States appealed a judgment from the United States Court of Appeals for the District of Columbia Circuit, which reversed the convictions of respondent individuals for narcotics possession and granted defendants' motion to suppress evidence obtained in a search of mail pursuant to 19 U.S.C.S. § 482.

Defendants were convicted of possession of narcotics. Key evidence against them was obtained when a customs officer searched international mail intended for respondents.

  • Holding that 19 U.S.C.S. § 482 authorized the search of letters, and that the "reasonable cause" standard of § 482 satisfied the Fourth Amendment, the court reversed the judgment. 
  • The court held that § 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," and noted that the congress that proposed the Bill of Rights also enacted the first customs statute authorizing such searches. 
  • The court also held that § 482 did not implicate the U.S. Constitutional Amendment I.


The court reversed the judgment that overturned respondent individual's convictions, because it was error to suppress evidence obtained in petitioner United State's search of letters intended for respondents, where the search was permitted by statute, and the statute's "reasonable cause" standard provided constitutionally adequate protections for searches of mail at the border.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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