Druggan v. Anderson

Background

A man was jailed for contempt after disobeying a temporary court order (an injunction) issued under Title II of the National Prohibition Act. The underlying bill said a place was a public nuisance used to make and sell intoxicating liquor and named the man among those running the business. After a contempt information was filed he was fined and sentenced to one year, and he asked a court to free him from jail through a habeas corpus petition. He argued the enforcement law was invalid because Congress passed Title II on October 28, 1919, less than a year after the Eighteenth Amendment was ratified on January 16, 1919.

Reasoning

The central question was whether the Amendment existed only when its one-year prohibition date arrived, or whether it existed upon ratification. The Court said the Amendment became effective as law when ratified, even though its words prohibited certain acts only after a year. That meant Congress had authority to pass laws in support of the Amendment before the later operative date. The Court also considered an argument that the temporary order lacked required notice and said even if notice were needed, the injunction could not be ignored as void. For these reasons the Court affirmed the dismissal of the habeas petition and left the contempt sentence in place.

Real world impact

The decision allows enforcement laws tied to a constitutional amendment to be enacted before the amendment’s delayed effective date. It upholds the ability to close and punish operators of alleged liquor nuisances and confirms that missing notice does not automatically void a temporary injunction.