Joplin Mercantile Co. v. United States

Background

A Missouri company and an individual were indicted for conspiring to send packages of intoxicating liquor from Joplin, Missouri, to Tulsa and other places in Oklahoma that the indictment described as part of the Indian country. The defendants were tried, convicted, and the Court of Appeals affirmed on the question whether the indictment charged an offense under federal law. The defendants asked this Court to decide whether federal laws banning liquor traffic into Indian country still applied after Oklahoma became a State under the Enabling Act.

Reasoning

The Court examined three federal laws: the acts of 1892 and 1897 (which prohibit introducing liquor into Indian country) and the 1895 act (which broadly forbade carrying liquor within Indian Territory). The Court held that the acts of 1892 and 1897 remain effective against introductions into Indian country, but that the 1895 law’s internal, intrastate enforcement is suspended so long as Oklahoma’s constitution and laws, adopted under the Enabling Act, impose their own state prohibition. The Court also found the conspiracy allegation sufficient because it charged an agreement to introduce liquor into parts of the State that were still Indian country.

Real world impact

The decision affirms criminal liability for planning to bring liquor into areas the law treats as Indian country and confirms that federal bans in the 1892 and 1897 acts still operate. At the same time, it recognizes that the State’s temporary internal prohibition, imposed by the Enabling Act, displaces enforcement of the 1895 intrastate rule while the state prohibition remains in force.