Maul v. United States
Headline: Court upholds Coast Guard power to seize American coastwise vessels beyond twelve miles, allowing federal officers to take custody of U.S. ships on the high seas when revenue or navigation laws are violated.
Holding: The Court held that Coast Guard officers lawfully may seize an American coastwise vessel on the high seas beyond twelve miles when the ship has become liable to forfeiture for violations of laws protecting the revenue.
- Allows Coast Guard to seize U.S. vessels beyond twelve miles for forfeiture offenses.
- Strengthens federal power to enforce navigation and customs laws at sea.
- Makes it harder for vessel owners to avoid penalties by leaving coastal waters.
Summary
Background
An American coastwise ship called the Underwriter was seized by Coast Guard officers in December 1924 about thirty-four miles from the coast. The Government filed a civil forfeiture claim because the ship sailed on a foreign voyage without giving up its coastwise enrollment and license and was used in a trade different from that for which it was licensed, making the vessel liable to forfeiture. The owner challenged the seizure as beyond the Coast Guard’s authority; a trial court dismissed the case, the Court of Appeals reversed, and the case came to this Court for review.
Reasoning
The central question was whether Coast Guard officers could lawfully seize a U.S. vessel on the high seas more than twelve miles from shore. The Court looked at long-standing customs and revenue statutes and concluded that officers charged with enforcing the revenue are authorized to seize vessels “as well without as within their respective districts.” The Court treated Coast Guard officers as customs officers and held that the 1922 statute did not repeal the broader seizure authority. Because the ship’s violations concerned laws protecting the revenue, the Court found the seizure lawful and upheld the forfeiture grounds.
Real world impact
The decision confirms that federal enforcement at sea can reach U.S. vessels beyond the twelve-mile coastal band when those vessels are liable to forfeiture for revenue or navigation-law violations. Vessel owners can no longer avoid seizure simply by moving well offshore; federal officers have authority to take custody of offending American ships on the high seas. The case did not decide issues about boarding and searching to detect smuggling.
Dissents or concurrances
Justice Brandeis concurred in the judgment but disagreed with the Court’s statutory reading. He would rest the authority on an implied power as part of the Coast Guard’s ocean-patrol duties; Justice Holmes joined that opinion.
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