Alston v. United States

Background

A man named Alston was indicted in federal court for buying morphine and cocaine from packages that lacked the required tax-paid stamps under a federal narcotics law. He pleaded guilty, was sentenced to prison, and sought review that brought the record to the highest Court to decide whether the amended law and his conviction were valid.

Reasoning

The Court examined the 1919 amendments that imposed a small internal tax on opium, coca leaves, and their preparations, and required taxes to be shown by stamps affixed so as to seal the package. The amendments also made it unlawful to buy, sell, or distribute these drugs except in original stamped packages and treated absence of stamps as prima facie evidence of violation. Alston argued there was no specific punishment for buying from unstamped packages and that Congress exceeded its powers. The Court held that the law’s general penalty provision applies to violations of the amended rules and that Congress validly imposed the tax and stamp requirement as a legitimate exercise of its taxing power.

Real world impact

The ruling means federal tax-stamp rules on narcotics are enforceable, and buying or selling morphine or cocaine from unstamped packages can lead to conviction under the law’s general penalty. The decision affirms that Congress can use taxation to regulate these drugs and does not, on its face, unlawfully invade state powers.