The case of One Lot Emerald Cut Stones and One Ring v. United States in 1972 revolved around the seizure by U.S. Customs officials of a lot of emerald cut stones and one ring, which were imported into the country without declaration, thus violating customs laws. The items were seized from Gilbert Zeehandelaar who claimed that he was unaware they needed to be declared upon entry into the U.S., as he had purchased them abroad for his personal use only. However, under Section 1497 of Title 19 (Customs Duties) any articles not declared on arrival are subject to forfeiture regardless if there was an intent to defraud or not. The Supreme Court upheld this law stating that it serves a valid governmental purpose - ensuring compliance with import restrictions and duties - therefore does not violate due process rights even though it is harsh in nature.

In the dissenting opinion for ONE LOT EMERALD CUT STONES AND ONE RING v. UNITED STATES, 1972, Justice Douglas argued that the forfeiture of property used in illegal activities should not be applied to innocent owners who had no knowledge of any wrongdoing. He contended that this interpretation was consistent with both historical precedent and basic principles of fairness. The majority's ruling allowed for a harsh penalty on an individual who did nothing wrong and knew nothing about the crime committed by another person using their property. This contradicted traditional American values such as due process and protection from excessive fines or cruel punishment, according to Justice Douglas' dissenting view.