United States v. Jin Fuey Moy

Background

A man was indicted for conspiring with another person, Willie Martin, to have a small amount of morphine in Martin’s possession. Martin had not registered with the internal revenue collector or paid the special tax the law requires. The defendant allegedly gave Martin a written prescription not issued in good faith. The District Court quashed the indictment, saying the law did not apply to this case.

Reasoning

The Court examined a 1914 law that requires registration and a small annual tax for people who produce, sell, or deal in opium and similar drugs, and that also contains a section making it unlawful for “any person” not registered to possess such drugs. The Government argued the words should be read broadly; the Court instead read the law to avoid serious constitutional doubts. The Court noted the law’s structure, its focus on people required to register, and the heavy criminal penalties, and concluded the phrase “any person not registered” refers to the class that the law targets—those required to register—rather than every person in the country. The Court therefore affirmed the District Court’s ruling.

Real world impact

The decision limits federal criminal exposure for ordinary individuals who possess small quantities of opiates and focuses the law’s reach on unregistered dealers and businesses that the registration rules cover. It preserves the law’s registration and tax scheme for commercial actors while preventing broad criminalization of private possession under §8. The ruling resolves this case but does not eliminate other federal or state drug laws.

Dissents or concurrances

Two Justices, Hughes and Pitney, dissented from the Court’s conclusion; the majority nonetheless affirmed the judgment.