United States v. $124,570 U.S. Currency, Appeal of Wayne G. Campbell, Claimant-Appellant

Like more than a billion other airline passengers last year, Wayne G. Campbell passed through an airport security check on his way to a flight. During the course of the screening, the security officer discovered a large quantity of U.S. currency. Pursuant to an established arrangement, the officer notified agents of the United States Customs Service who paid her $250 for the tip. The tip led to Campbell’s detention and confiscation of the currency.

Campbell challenges the legality of the search, raising fundamental questions about the extent to which law enforcement authorities may use airport security inspections to promote objectives unrelated to air safety.

I

On January 5, 1987, Campbell placed his locked briefcase on a conveyor belt leading through an x-ray scanner operated by United Airlines at the Seattle International Airport. Picking up a dark mass on the x-ray screen, the Flight Terminal Security (FTS) officer operating the scanner, Bonnie Boswell, asked Campbell to open the briefcase. First expressing reluctance, Campbell eventually agreed to do so privately, behind a screen. FTS officer Karen Kangas searched the case and found a very large quantity of currency.…