National Safe Deposit Co. v. Stead
In National Safe Deposit Co. v. Stead, 232 U.S. 58 (1914), the U.S. Supreme Court held that the Fourth Amendment does not apply in state court proceedings. A bank had objected to state law that required banks to seal safe deposit boxes after the owner's death, and take assets from it to pay the inheritance tax.
The Court upheld the constitutionality of the law by holding that:
- The objection that the act, in directing the state officers to inspect the contents of the box, operates as an unreasonable search and seizure raises no Federal question, since the prohibition on that subject in the Fourth Amendment, does not apply to the States. Ohio ex rel. Lloyd v. Dollison, 194 U.S. 445, 447.
This statement was overruled in Mapp v. Ohio.