United States v. Lanza

Background

A group of people were charged in federal court for making, transporting, and possessing alcohol and for having a still and materials around April 1920 under the National Prohibition Act. The five federal counts accused them of manufacturing, transporting, possessing, and having a still and materials for making liquor. They told the federal court that a Washington state court had already charged them on April 16, 1920, and fined each defendant $250 for making, transporting, and possessing the same liquor. The defendants filed a special plea in bar, and the federal judge accepted this argument and dismissed the federal counts.

Reasoning

The Court examined the Eighteenth Amendment and explained that its first section forbids manufacture, sale, or transportation of intoxicating liquors nationwide, while the second section preserves both Congress’s and each State’s separate power to pass enforcement laws. The opinion explains that states retained the power to forbid and punish such acts from their own authority, and those state laws do not derive from the amendment. The Court emphasized that the Fifth Amendment’s protection against being punished twice applies only to punishments by the federal government. Because state and federal governments are separate sovereigns, the same act can be an offense against each, so a state conviction or fine does not automatically bar a federal prosecution under the Prohibition law.

Real world impact

The decision lets federal prosecutors proceed against people already punished by a state for making or moving liquor unless Congress says otherwise. It prevents state fines from automatically giving offenders immunity from federal charges and preserves federal authority to enforce national prohibition rules. The ruling reverses the federal court’s dismissal and sends the case back for further federal proceedings.