Pabst Brewing Co. v. Crenshaw
Headline: State beer-inspection law upheld, allowing Missouri to collect inspection fees on beer received and held for sale and affecting out-of-state brewers shipping into the State.
Holding: The Court ruled that Missouri’s inspection law applies to beer shipped into the State after delivery, and validly authorizes inspection and fees under the federal Wilson Act, so the state may enforce those charges.
- Allows states to inspect and charge fees on beer received and held for sale.
- Requires out-of-state brewers to provide affidavits and pay inspection fees.
- Affirms states’ power to apply health rules to liquor after arrival.
Summary
Background
A Wisconsin brewer sued Missouri’s beer inspector to block collection of inspection fees that Missouri imposed on beer when it arrived in the State and was held there for sale. The Missouri law created an inspector, required labels and affidavits about beer ingredients, and set inspection fees and stamps for packages. The brewer argued the fees and rules were an unlawful regulation of interstate commerce and discriminated against out-of-state beer.
Reasoning
The Court’s majority focused on a federal law (the Wilson Act) saying liquors brought into a State become subject to that State’s laws after arrival. Relying on prior decisions, the Court concluded Missouri’s law was a valid exercise of the State’s power to regulate for public health and purity, so it could inspect, label, and charge fees for beer held for sale. The Court rejected arguments that the law was an improper regulation of interstate commerce simply because it produced revenue or might indirectly discourage shipments.
Real world impact
The decision lets Missouri enforce inspection, labeling, and fee rules on beer delivered and held for sale in the State. Out-of-state brewers who ship into Missouri must follow the affidavit and labeling rules and pay fees. The ruling affirms that, under the Wilson Act, States can apply their health-and-safety rules to intoxicating liquors after arrival.
Dissents or concurrances
A dissent argued the inspection was only an affidavit, not a real check; fees far exceeded inspection costs (fees about $350,000 versus $12,500 expense), suggesting the law functioned mainly as a revenue measure and unlawfully burdened interstate commerce.
Opinions in this case:
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