United States v. Sprague

Background

The United States is appealing a district court order that quashed an indictment charging several people with transporting and possessing intoxicating liquor under the National Prohibition Act. The district court concluded the Eighteenth Amendment had not been ratified. The defendants argued Article V, which explains how to amend the Constitution, must be read to require state conventions rather than state legislatures when an amendment affects people’s personal liberties.

Reasoning

The Court considered whether Article V plainly lets Congress choose which ratification method to propose and whether the Tenth Amendment bars that choice. It held Article V’s language is clear: Congress may propose whether amendments are ratified by state legislatures or by state conventions. The justices rejected the defendants’ argument that the framers’ views about adopting the original Constitution require a different rule now. The Court also said the Tenth Amendment does not change Article V’s grant of authority to Congress. Citing earlier cases and the fact that many amendments affecting citizens’ rights were ratified by legislatures, the Court concluded the Eighteenth Amendment was lawfully ratified and reversed the district court.

Real world impact

The immediate result is that the district court’s order is reversed, clearing the way for federal prosecution under the National Prohibition Act to proceed. More broadly, the ruling confirms that Congress decides the ratification method, making legal challenges that seek to require state conventions less likely to succeed.

Dissents or concurrances

The Chief Justice took no part in the consideration or decision of this case.