Boyd v. United States


Significance: The Supreme Court made expansive interpretations of the constitutional guarantees against compulsory self-incrimination and unreasonable searches and seizures.

The federal government charged New York merchants George Boyd and Edward Boyd with a civil offense for importing plate glass without paying the required duty. Using a federal statute, officials obtained a court order instructing the Boyds to produce the invoices for the goods. When the invoices were used as evidence, the Boyds claimed that the government had violated their rights under the Fourth and Fifth Amendments. The government argued that there had been no physical invasion of property and that the amendments applied only to criminal trials. A unanimous Supreme Court ruled in favor of the Boyds and found part of the customs statute unconstitutional. Justice Joseph P. Bradley reasoned that the Fourth and Fifth Amendments combined with the common law to protect “the sanctity of a man's house and the privacies of life.” The Fourth Amendment protected individuals from any procedures that had the same effect as a physical search. It applied to all proceedings with government penalties and permitted searches only for contraband articles not for mere evidence of an illegal action. A warrantless seizure, moreover, violated the Fifth Amendment prohibition against compulsory self-incrimination. Bradley declared that the courts should guard against any “stealthy encroachments” of constitutional rights. The Boyd decision was a watershed in providing a liberal interpretation of privacy rights by joining the Fourth and Fifth Amendments to common law principles. Also, the decision initiated the development of the exclusionary rule. Boyd's mere evidence rule, however, was eventually abandoned in Warden v. Hayden (1967).