Heyman v. Southern Railway Co.

Background

A Georgia whiskey wholesaler shipped two casks to buyers who lived in Charleston, South Carolina. The goods reached Charleston and were unloaded by the railroad into its warehouse and held ready for delivery. The record does not show the buyers were given notice. Local constables then seized the whiskey under South Carolina’s dispensary law without a warrant, and the railroad’s agent did not resist. The wholesaler sued the railroad for failing to deliver; Georgia courts sided with the State, and the case reached this Court.

Reasoning

The key question was when a transported shipment becomes subject to a State’s police rules under the federal Wilson Act — in ordinary words, when does the State get authority to regulate or seize goods brought in from another State. The Court reviewed prior decisions and concluded that the Wilson Act’s word “arrival” means the shipment is not under state control until it has been delivered to the consignee (and sale in the original package is a recognized endpoint). Warehousing the goods before delivery does not, by itself, let a State seize them. Because delivery had not occurred before the seizure, the State’s action was not lawful under the Wilson Act, and the Georgia court’s construction of “arrival” was wrong.

Real world impact

The decision protects out-of-state sellers and carriers from state seizure of shipped liquor kept in a carrier’s warehouse before delivery. It leaves open, however, questions about situations where a consignee is given notice but intentionally leaves goods with the carrier for an unreasonable time; the Court said those facts were not before it. The Court reversed the Georgia judgment and sent the case back for further proceedings consistent with this ruling.