Cite as: 510 U. S. 43 (1993)
Opinion of Rehnquist, C. J.
we expressly stated that the Fourth Amendment "applies in the civil context as well." Our historical treatment of civil forfeiture procedures underscores the notion that the Fourth Amendment specifically governs the process afforded in the civil forfeiture context, and it is too late in the day to question its exclusive application. As we decided in Calero-Toledo v. Pearson Yacht Leasing Co., 416 U. S. 663 (1974), there is no need to look beyond the Fourth Amendment in civil forfeiture proceedings involving the Government because ex parte seizures are " 'too firmly fixed in the punitive and remedial jurisprudence of the country to be now displaced.' " Id., at 686 (quoting J. W. Goldsmith, Jr.-Grant Co. v. United States, 254 U. S. 505, 510-511 (1921) (forfeiture not a denial of procedural due process despite the absence of preseizure notice and opportunity for a hearing)).
The Court acknowledges the long history of ex parte seizures of real property through civil forfeiture, see Phillips v. Commissioner, 283 U. S. 589 (1931); Springer v. United States, 102 U. S. 586 (1881); Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856); United States v. Stowell, 133 U. S. 1 (1890); and Dobbins's Distillery v. United States, 96 U. S. 395 (1878), and says "[w]ithout revisiting these cases," ante, at 59—whatever that means—that they appear to depend on the need for prompt payment of taxes. The Court goes on to note that the passage of the Sixteenth Amendment alleviated the Government's reliance on liquor, customs, and tobacco taxes as sources of operating revenue. Whatever the merits of this novel distinction, it fails entirely to distinguish the leading case in the field, Phillips v. Commissioner, supra, a unanimous opinion authored by Justice Brandeis. That case dealt with the enforcement of income tax liability, which the Court says has replaced earlier forms of taxation as the principal source of governmental revenue. There the Court said:
"The right of the United States to collect its internal revenue by summary administrative proceedings has
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