United States v. Wright

Background

A man was indicted for bringing a quart of whiskey into what had been Indian Territory in Muskogee County, Oklahoma. The indictment charged violation of a federal law that prohibits introducing intoxicating liquor into Indian country. The District Court sustained the defendant’s demurrer and dismissed the indictment after concluding that Congress’s Enabling Act and Oklahoma’s admission as a State had repealed the federal laws as to intrastate introductions.

Reasoning

The main question was whether the federal statutes from 1892 and 1897 that bar bringing liquor into Indian country were impliedly repealed by the Oklahoma Enabling Act and statehood. The Court reviewed the text and history of the 1892, 1895, and 1897 statutes, the Enabling Act, and prior decisions. It explained that the 1895 law—aimed specifically at the Territory—was treated differently from the broader 1892 and 1897 laws. The Enabling Act reserved federal authority over Indians and did not plainly wipe out the federal prohibitions. Reading the statutes together, the Court found no clear, necessary repugnancy that would show an implied repeal of the 1892 and 1897 laws.

Real world impact

The Court concluded the District Court erred and reversed the dismissal, sending the case back for further proceedings under the federal statutes. Practically, federal prohibition against introducing liquor into Indian country remains enforceable after Oklahoma’s admission where those federal protections apply, so prosecutions under those laws may proceed.