United States v. Lee
Headline: Court allows Coast Guard to board and seize American boats beyond twelve miles for suspected liquor smuggling, upholding arrests and evidence even without immediate forfeiture proceedings, shaping high-seas enforcement.
Holding: The Court ruled that the Coast Guard may lawfully board, search, and seize an American vessel beyond twelve miles when officers have reason to believe revenue laws are being violated, and evidence from that seizure is admissible.
- Allows Coast Guard to board American vessels beyond twelve miles with reasonable cause.
- Permits arrests on such vessels and use of resulting evidence in court.
- Failure to start forfeiture proceedings does not undo lawful seizure or evidence.
Summary
Background
A man named Lee and two companions were arrested on a small motor boat about 24 miles from shore, alongside a schooner in an area called Rum Row. The Coast Guard boatswain found 71 cases of grain alcohol on the motor boat, took the men, the boat, and the liquor to Boston, and the men were indicted for conspiring to violate federal revenue and prohibition laws. A lower federal court convicted Lee, but the Court of Appeals threw out the conviction because it said the search and seizure at sea were illegal.
Reasoning
The Supreme Court considered whether Coast Guard officers may board, search, arrest, and seize an American vessel on the high seas beyond the twelve-mile limit when there is reason to believe federal revenue laws are being broken. The Court held that under the relevant statutes the Coast Guard may seize such a vessel and, when officers have a reasonable belief of wrongdoing, may board and arrest those on board. The Court also found the use of a searchlight and the subsequent examination in Boston were lawful, and that failing to begin forfeiture proceedings afterward does not retroactively make the seizure illegal.
Real world impact
The ruling means federal officers can act against suspected smuggling on American boats well beyond the twelve-mile coastal limit, arrest suspects, and use evidence gathered from the seizure in court. It treats boarding and searches on the high seas for revenue violations similarly to law enforcement searches on land when officers have cause to suspect a crime.
Dissents or concurrances
A judge on the Court of Appeals dissented from that court’s decision, arguing the search was unlawful; the Supreme Court disagreed and reversed the appeals court.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?