American Express Co. of NY v. Kentucky
Headline: Court affirmed conviction, ruling that a shipping company cannot collect payment for whiskey sent into a dry district, preventing carriers from acting as payment-collecting agents despite interstate-shipping claims.
Holding: The Court affirmed the conviction of the express company, holding it cannot, under interstate-commerce protections, accept payment for whiskey shipped into a local-option district or act as a collecting agent in violation of state law.
- Stops carriers from collecting COD payments for alcohol sent into dry districts.
- Increases legal risk for shipping companies handling alcohol C.O.D. deliveries.
- May reduce similar lawsuits by clarifying carriers’ duties under state law.
Summary
Background
A shipping company was prosecuted under a Kentucky law for accepting cash-on-delivery (C.O.D.) shipments of whiskey into a local-option (dry) district. At a jury trial the company was found guilty and fined $100. The company appealed, the Kentucky Court of Appeals affirmed, and the case reached the U.S. Supreme Court. The record included conflicting testimony about whether the consignee had actually placed the order and whether the carrier knew the package contained whiskey.
Reasoning
The Court addressed whether an express or shipping company could use interstate-commerce protection to accept payment for alcohol shipped into a district where state law forbids such sales. The Court explained that a carrier does not have a right to assume duties beyond those required of it and may not do what state law forbids simply because the shipment crossed state lines. Given the Attorney General’s arguments and the evidence, the Court found this case substantially like earlier ones and therefore affirmed the conviction and judgment against the company.
Real world impact
The decision makes clear that shipping companies cannot serve as collecting agents for alcohol sales into local-option districts and cannot rely on interstate-commerce claims to override state alcohol laws. Carriers face increased legal risk when they accept C.O.D. payments for alcoholic shipments into dry areas. The ruling upholds the lower courts’ judgments and resolves this prosecution in favor of the State.
Dissents or concurrances
Justice Harlan dissented, saying these transactions were not legitimate interstate commerce but were devices to evade Kentucky’s alcohol-sale laws.
Opinions in this case:
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