Mahoney v. Joseph Triner Corp.

Background

An Illinois liquor maker, Joseph Triner Corporation, made alcohol in Illinois and lawfully registered to sell at wholesale in Minnesota after complying with Minnesota's foreign corporation law and getting a Minnesota license. In 1935 Minnesota passed Chapter 390, banning licensed manufacturers or wholesalers from importing any brand of liquor over 25% alcohol ready for sale unless that brand was registered in the U.S. Patent Office. Triner had a stock of such unregistered high‑alcohol brands in Minnesota and sued Minnesota officials claiming the law violated the Fourteenth Amendment’s equal protection guarantee. A three‑judge federal court froze enforcement and issued a permanent injunction, and Minnesota appealed.

Reasoning

The Court addressed whether the Fourteenth Amendment’s equal protection rule prevents a State from discriminating against imported intoxicating liquor. Relying on the text of Section 2 of the Twenty‑first Amendment, which bars importation into a State in violation of its laws, the Court concluded that the Amendment permits States to treat imported liquor differently from locally processed products. The Court declined to rewrite the Amendment to limit the State’s power based on what a court might view as a reasonable regulation. Because the Twenty‑first Amendment authorized discrimination against imports, the equal protection objection failed and the injunction was reversed.

Real world impact

The decision lets Minnesota and similar States bar or favor certain imported spirits based on registration and processing rules, even if that creates unequal treatment between out‑of‑state and in‑state products. The ruling also means licenses and existing stocks can be affected when States change their alcohol rules. The opinion is final for this appeal; the Court noted States independently may end licenses apart from the Amendment.

Dissents or concurrances

Justice Reed agreed with the result; Justice Cardozo did not participate.