People v. Dworkin, 30 N.Y.2d 706 (1972)
Border searches by customs officials do not require probable cause, and any vehicle, person, or baggage entering the United States is subject to search; contraband seized during a reasonable border search is admissible as evidence.
Summary
The New York Court of Appeals affirmed an order denying the suppression of marijuana found in the defendants’ car during a border search. The court held that border searches do not require probable cause; customs officials have the authority to stop and examine vehicles entering the U.S. The mere act of crossing the border provides sufficient basis for a search. The court reasoned that, absent a showing that the search was unreasonable in its execution, contraband found during the search is admissible as evidence. The presence of antidraft literature in the car was irrelevant to the legality of the search.
Facts
The defendants were traveling in a vehicle that crossed the U.S. border. At a border checkpoint, customs officials stopped and searched the vehicle. During the search, officials discovered marijuana. The defendants moved to suppress the marijuana as evidence, arguing that the search was unconstitutional. The defendants contended that the customs inspector lacked any specific reason to suspect they possessed marijuana, noting that the inspector observed antidraft literature in the car before the search.
Procedural History
The trial court initially heard the motion to suppress. The trial court denied the motion. The Appellate Division affirmed the denial of the motion to suppress. The case then went to the New York Court of Appeals.
Issue(s)
Whether marijuana found in an automobile during a border search should be suppressed as evidence because the search was conducted without probable cause or reasonable suspicion.
Holding
No, because border searches need not be based on probable cause, and customs officials are permitted to stop and examine any vehicle entering the United States; contraband seized during a border search is admissible as evidence unless the search was unreasonable in its execution.
Court’s Reasoning
The Court of Appeals relied on the established principle that border searches are distinct from other types of searches and seizures. Citing Carroll v. United States, the court emphasized the broad authority of customs officials to conduct searches at the border. The court stated that “[t]he mere crossing of the border is a sufficient basis for a search.” The court reasoned that, once the defendants arrived at the checkpoint, they were legitimately subjected to questioning and a search of their vehicle. The court dismissed the relevance of the antidraft literature, stating that it did not affect the legality of the border search. The court implicitly adopted a balancing test, weighing the government’s interest in controlling its borders against the individual’s right to privacy. It found that the government’s interest outweighed the individual’s in the context of border crossings, justifying a lower standard than probable cause. The court did not elaborate on what might constitute an unreasonable border search, focusing instead on the principle that the mere crossing of the border is sufficient justification. No dissenting or concurring opinions were noted.