In the Montoya v. United States case of 1900, the U.S Supreme Court ruled in favor of the government's right to detain and inspect goods imported into the country for customs duties. The dispute arose when a woman named Jesusa Montoya was detained at a New York port by customs officials who suspected her of smuggling diamonds from Venezuela. She was held for over two days while her belongings were searched thoroughly but no contraband items were found. Consequently, she sued for false imprisonment and won in lower courts which ordered compensation be paid to her by federal officers involved. However, on appeal to the Supreme Court, it reversed these decisions stating that customs officials had acted within their rights under international law and U.S statutes which allowed them reasonable time necessary to ascertain whether goods brought into America are subject to duty or should be confiscated due its illegal nature. It further clarified that this power extended not only over merchandise itself but also containers holding them including travelers' baggage as well as persons believed concealing such articles about their body.

In the dissenting opinion for Montoya v. United States, Justice Harlan argued that the majority's decision was a violation of personal liberty and property rights. He believed that it was unconstitutional to detain an individual without any evidence or reasonable suspicion of wrongdoing, even at border crossings where customs officials have broad powers to inspect goods entering the country. Furthermore, he contended that such detention could not be justified merely on grounds of administrative convenience or efficiency in enforcing immigration laws. In his view, this approach essentially presumed guilt until innocence could be proven which is contrary to fundamental principles of American law and justice system.