Cline v. Frink Dairy Co.

Background

Three Colorado dairy companies and several individual dairy businessmen sued the Denver district attorney after he filed a criminal information under Colorado’s Anti‑Trust Act and threatened further prosecutions and civil suits to forfeit corporate charters. They asked a federal court to block the officer from enforcing the state law, saying it would destroy their businesses because the statute failed to give fair notice of what conduct was criminal.

Reasoning

The Court considered whether the statute gave people a clear standard of criminal guilt. It compared the Colorado law to earlier cases and explained that the Act’s broad prohibitions plus two provisos left juries and defendants guessing about what profit levels or practices were lawful. Because the law required juries to decide complex economic questions—such as whether certain trust methods were necessary to obtain a “reasonable profit”—the Court found the statute unconstitutionally vague under the Fourteenth Amendment’s guarantee of fair legal process. The Court therefore held the Act invalid for criminal enforcement, but it narrowed the lower court’s injunction so it would not bar prosecutions already pending in state court.

Real world impact

The ruling protects the named dairy plaintiffs from threatened future prosecutions under this Colorado statute and constrains the State’s ability to enforce the law going forward. At the same time, existing criminal proceedings that were already underway in state court were allowed to continue. The decision emphasizes that states must draft criminal business laws with clear, definite standards.

Dissents or concurrances

A judge below dissented about the breadth of the injunction; the Supreme Court agreed that stopping prosecutions already pending was too broad, so it narrowed that part of the relief.