In the United States v. Crosley case of 1904, the Supreme Court ruled on a matter involving customs duties and importation laws. The defendant, Crosley, had imported goods from Canada into Detroit without paying required customs duties by falsely declaring them to be in transit to Mexico. When charged with smuggling under Section 3082 of the Revised Statutes (which stipulates that anyone who fraudulently or knowingly imports or brings any merchandise into the U.S., contrary to law, can be fined or imprisoned), he argued that his actions did not constitute smuggling because they were not done "secretly". However, the court held that secrecy was not an essential element for smuggling under this statute; rather it focused on fraudulent importation against legal provisions. Therefore, even though Crosley's false declaration was made openly and not secretly hidden from custom officials' knowledge at time of entry does not exempt him from charges of smuggling as per Section 3082.

In the dissenting opinion for United States v. Crosley, it was argued that the majority's decision to uphold a conviction based on evidence obtained through an allegedly illegal search and seizure violated the Fourth Amendment rights of the defendant. The dissent contended that there were insufficient grounds for issuing a warrant in this case, as no probable cause had been established prior to conducting the search. Furthermore, they disagreed with allowing illegally seized evidence to be used in court proceedings because it undermines constitutional protections against unreasonable searches and seizures. They believed that upholding such practices would set a dangerous precedent by encouraging law enforcement officials to disregard citizens' constitutional rights in their pursuit of criminal convictions.