Thus, as early as 1988 in Simmons v. The Queen, 1988 CanLII 12 (SCC), 45 C.C.C. (3d) 296 (S.C.C.) Dickson C.J.C. held that certain searches conducted at border entry points raise no constitutional issues: …the cases and the literature seem to recognize three distinct types of border search. First is the routine of questioning which every traveller undergoes at a port of entry, accompanied in some cases by a search of baggage and perhaps a pat or frisk of outer clothing. No stigma is attached to being one of the thousands of travellers who are daily routinely checked in that manner upon entry to Canada and no constitutional issues are raised.
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