The purpose of this Note is to examine the fourth amendment implications of the holding in Villamonte-Marquez. The Note will examine the Court's treatment of Section 1581(a) under which the search arose, analyze the judicial treatment of the decisions relied on by the Court and criticize the Court's treatment of the "reasonableness" of the governmental intrusion. The Note concludes that because private cabin-boaters have great interests against arbitrary intrusion by officials, cases such as Villamonte-Marquez should be scrutinized more carefully to preserve the protection of the fourth amendment.
Wallace R. Young Jr., Criminal Procedure - Vessels in Inland Waters Are Subject to Suspicionless Boarding - United States v. Villamonte-Marquez, 6 Campbell L. Rev. 183 (1984).