James Everard's Breweries v. Day

Background

A New York brewery and a British bottling company challenged a new federal law that forbids doctors from prescribing beer and other intoxicating malt liquors for medicinal use. Earlier federal rules and an Attorney General opinion had allowed permits for making and prescribing medicinal malt liquors. The Supplemental Prohibition Act then added a rule saying only distilled spirits and wines could be prescribed, voiding permits and prescriptions for malt liquors. The companies had large stocks or had been denied permits and sued to stop enforcement; lower courts dismissed their cases, and the appeals reached this Court.

Reasoning

The main question was whether Congress, under the Eighteenth Amendment, could ban doctors from prescribing malt liquors to better enforce the nationwide ban on alcoholic beverages. The Court said Congress may use measures reasonably adapted to make prohibition effective, and it owes deference to Congress’s factual findings. Congress held hearings, found little medical need for beer as a remedy, and concluded allowing malt liquor prescriptions would open doors to disguised beverage sales. The Court found that banning such prescriptions had a real relation to enforcing prohibition and was not arbitrary, so the federal rule was constitutional.

Real world impact

The decision lets federal officials refuse permits and stops doctors and pharmacists from legally using beer and similar products as medicines, forcing producers to stop medicinal sales and often dispose of stock. The ruling favors broad federal power to cut off channels that could be used to evade the national ban, while still permitting limited prescriptions of certain spirits and wines under the law’s quantity limits.