United States v. Van Leeuwen
1970 U.S. LEXIS 57, 25 L. Ed. 2d 282, 397 U.S. 249 (1970)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
First-class mail, while protected by the Fourth Amendment against unreasonable searches, may be detained without a warrant for a limited and reasonable time based on reasonable suspicion to allow authorities to investigate and obtain a search warrant.
Facts:
- On Thursday, March 28, 1968, at about 1:30 p.m., Van Leeuwen mailed two 12-pound packages at a post office in Mt. Vernon, Washington, a town near the Canadian border.
- One package was addressed to a post office box in Van Nuys, California, and the other to a post office box in Nashville, Tennessee; Van Leeuwen declared they contained coins, and mailed them airmail registered, insured for $10,000 each, making them first-class mail.
- A postal clerk, suspicious of the packages, informed a policeman who was present, and the policeman noticed that the return address on the packages was a vacant housing area of a junior college and that Van Leeuwen's car had British Columbia license plates.
- The policeman contacted Canadian police, who then called customs officials in Seattle.
- At 3:00 p.m. that afternoon, Seattle customs learned that the addressee of the California package was under investigation in Van Nuys for trafficking in illegal coins.
- The following morning, March 29, Seattle customs learned that the addressee of the Nashville package was also being investigated for the same crime.
- Van Leeuwen had brought the two packages from Canada without declaring them.
Procedural Posture:
- Van Leeuwen was tried in a United States district court for illegally importing gold coins in violation of 18 U.S.C. § 545 and was found guilty, sentenced, and fined.
- Van Leeuwen appealed his conviction to the United States Court of Appeals (appellant), arguing that the coins were improperly admitted as evidence because a timely search warrant had not been obtained.
- The Court of Appeals reversed Van Leeuwen's conviction, holding that the coins were improperly admitted into evidence.
- The United States (petitioner) filed a petition for a writ of certiorari to the Supreme Court of the United States.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Fourth Amendment prohibit the warrantless detention of suspicious first-class mail for approximately 29 hours while authorities investigate and obtain a search warrant?
Opinions:
Majority - Mr. Justice Douglas
No, the Fourth Amendment did not prohibit the detention of the suspicious first-class mail for approximately 29 hours because the delay was reasonable given the investigatory circumstances and did not invade the mail's privacy until a warrant was obtained. The Court affirmed that first-class mail is protected by the Fourth Amendment, drawing on precedents like Ex parte Jackson, which established that sealed packages in the mail are guarded from inspection as if in one's home and can only be opened with a warrant. However, the Court distinguished between inspection (search) and temporary detention (seizure). The nature and weight of the packages, the fictitious return address, and Van Leeuwen's British Columbia license plates in a border town justified the initial detention without a warrant for investigation. The initial 1.5-hour detention for investigation was not excessive. Once probable cause developed for the California package, and considering the unavoidable delay in contacting federal officials in Tennessee due to time differences to investigate the second addressee, the total 29-hour delay between mailing and warrant execution was not unreasonable. The Court reasoned that the significant Fourth Amendment interest lies in the privacy of the mail, and that privacy was not disturbed or invaded until a magistrate's approval for a search warrant was obtained. Detaining the packages for this limited time was deemed a prudent act rather than allowing them to enter the mail stream and then trying to locate them later if suspicions were confirmed.
Analysis:
This case clarifies the application of the Fourth Amendment to mail, establishing that while first-class mail enjoys significant privacy protection, it is not immune from temporary, warrantless detention based on reasonable suspicion. It differentiates between a 'seizure' (detention) and a 'search' (opening the mail), noting that the latter requires a warrant. The ruling provides a framework for law enforcement to investigate suspicious packages without immediately violating Fourth Amendment rights, balancing individual privacy interests with the government's need to prevent illegal activities. Future cases involving temporary seizures of personal property, especially in contexts with rapid movement of goods, will likely reference this decision for its reasonableness standard and its emphasis on the point at which privacy is actually invaded.
