United States v. Resnick
Headline: Court affirms that a 1928 federal hamper-size law does not criminalize making or selling two-quart produce hampers, leaving small two-quart containers outside the statute’s reach and defendants cleared.
Holding: The Court held that the 1928 produce-hamper statute does not criminalize manufacturing or selling two-quart metal hampers because the law covers only its nine listed sizes, none smaller than four quarts.
- Makes manufacturing and selling two-quart produce hampers legal under the 1928 federal hamper-size law.
- Limits federal regulation to nine specified hamper sizes, excluding containers under four quarts.
- Protects small-container makers from misdemeanor fines under this statute.
Summary
Background
Several people were charged under a 1928 federal law that sets standard sizes for produce hampers. The indictments said the defendants made or sold two-quart metal hampers that did not match the sizes listed in the law and did not meet tolerances or submit dimensions to the Secretary of Agriculture. Lower courts sustained demurrers and discharged the defendants, and the United States appealed to the high court.
Reasoning
The Court asked whether the law’s ban on hampers “that do not comply with this Act” reaches two-quart containers. The statute lists nine specific sizes based on a standard bushel and allows the Secretary to set tolerances only for those listed sizes. Two-quart hampers equal 134.4 cubic inches and are smaller than any size the law defines. The Court applied the rule that criminal laws must be read narrowly. It concluded the statute’s words plainly refer to the nine sizes named in the law, do not condemn two-quart hampers, and do not make manufacturing or selling such small hampers a misdemeanor. Because the indictments did not allege deception or that the containers purported to be one of the listed sizes, they did not state an offense under the statute.
Real world impact
The decision means makers and sellers of two-quart produce hampers are not criminally liable under this 1928 statute. Federal regulation under that Act remains limited to the nine specified sizes, and containers under four quarts are outside its scope. The judgments dismissing the charges were affirmed.
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