Loyola of Los Angeles Law Review Volume 12 Number 1 Article 8 12-1-1978 Mail Covers and the Fourth Amendment: United States v. Choate Doris Schaffer Follow this and additional works at: https://digitalcommons.lmu.edu/llr Part of the Law Commons Recommended Citation Doris Schaffer, Mail Covers and the Fourth Amendment: United States v. Choate, 12 Loy. L.A. L. Rev. 201 (1978). Available at: https://digitalcommons.lmu.edu/llr/vol12/iss1/8 This Recent Decision is brought to you for free and open access by the Law Reviews at Digital Commons @ Loyola Marymount University and Loyola Law School. It has been accepted for inclusion in Loyola of Los Angeles Law Review by an authorized administrator of Digital Commons@Loyola Marymount University and Loyola Law School. For more information, please contact
[email protected]. MAIL COVERS AND THE FOURTH AMENDMENT: UNITED STA TES v. CHOA4 TE In UnitedStates v. Choate,I the Ninth Circuit held that a mail cover 2 is not an unreasonable search and seizure in violation of the fourth amendment of the United States Constitution.3 The majority of the court recognized that the reasonableness of the mail cover procedure is to be measured by the criteria set forth in Katz v. United States,4 but did not find that an addressee seeks privacy with respect to the outside cover of his mail or that such an expectation would be reasonable. I. INTRODUCTION A mail cover is a surveillance of an addressee's mail conducted by postal employees at the request of law enforcement officials.5 While not expressly permitted by federal statute, a mail cover is authorized by postal regulations in the interest of national security and crime preven- tion,6 and permits the recording of all information appearing on the outside cover of all classes of mail.7 Under the regulations, the Chief 1.