Joseph S. Finch & Co. v. McKittrick

Background

Missouri passed a law forbidding licensed sellers from importing, buying, selling, receiving, or possessing alcoholic liquor made in any state Missouri designated as imposing discriminatory laws. The Attorney General issued certificates naming several states as ‘‘discriminating,’’ and the Supervisor of Liquor Control notified licensees that imports from those states would be unlawful. Out‑of‑state liquor manufacturers and a Missouri bottler sued in federal court, claiming the law violated the federal commerce power and parts of the Fourteenth Amendment. The district court denied injunctions and dismissed the suits, and the temporary restraining orders were continued pending appeal to this Court.

Reasoning

The central question was whether Missouri’s restriction conflicted with the federal power to regulate interstate commerce. The Court relied on the Twenty‑first Amendment and held that, in the area of intoxicating liquors, a State may forbid imports that do not comply with the conditions it prescribes. The Court concluded that the Twenty‑first Amendment limits the reach of the commerce argument in this context, and it affirmed the lower court’s rulings. Practically, Missouri prevailed and may enforce its ban on liquor from states it has certified as discriminatory.

Real world impact

The decision lets Missouri block specified out‑of‑state liquor from entering the state and restricts what Missouri licensees may sell. Out‑of‑state manufacturers face the loss of Missouri sales when so certified, and licensed sellers inside Missouri must follow the State’s import rules. The ruling rests chiefly on the Twenty‑first Amendment’s grant of authority over alcohol importation, not on a final adjudication of every other constitutional claim alleged in the suits.