In the 1901 U.S. Supreme Court case, Fourteen Diamond Rings v. United States, Emil J. Pepke claimed fourteen diamond rings that were seized by customs officials upon his arrival in New York from Paris due to non-payment of duties. The court ruled against Pepke and upheld the seizure as lawful under Section 2809 of the Revised Statutes which allows for forfeiture of goods not declared on a passenger's manifest or baggage declaration form when entering into the country. This decision was based on evidence showing that Pepke had intentionally concealed these items with an intent to defraud revenue laws by avoiding paying import taxes on them.

In the dissenting opinion for the case Fourteen Diamond Rings, Emil J. Pepke, Claimant v. United States (1901), it was argued that there was a lack of sufficient evidence to prove that the diamond rings were imported illegally and therefore subject to seizure by U.S customs officials. The dissenting justices believed that mere suspicion or belief without concrete proof should not be enough grounds for confiscation of property under forfeiture laws. They contended that such an approach would lead to potential abuses of power and infringe upon individual rights protected by law. Furthermore, they disagreed with the majority's interpretation of "probable cause," arguing instead for a stricter standard in determining whether goods are liable for seizure due to illegal importation.