Seaboard Air Line Railway v. North Carolina

Background

The case involves a North Carolina law that required express and railroad companies to keep a special book listing every shipment of intoxicating liquor, with delivery details and the consignee’s signature, and to let officers or citizens inspect that book. A citizen named R. L. Davis went to a carrier’s office during business hours and asked to inspect the book; the carrier’s agent refused. The carrier was indicted in Wake County for violating the inspection requirement and was found guilty by the North Carolina courts.

Reasoning

The carrier argued the state law was invalid because it tried to regulate interstate shipments and conflicted with a federal law that bars carriers from disclosing shipment details except in certain situations. The Court rejected those arguments. It relied on a recent federal law (the Webb-Kenyon Act) that made shipments of intoxicating liquor subject to state control when the liquor would be received or used in violation of state law, and concluded the state could require publicity about shipments. The Court explained that the federal carrier-disclosure rule was meant for matters under exclusive federal control, but Congress had later allowed states to regulate these liquor shipments, so the state condition could stand. The Court affirmed the state court’s judgment.

Real world impact

Carriers doing business in North Carolina must keep shipment books and allow inspection by citizens or officers during business hours when the state law applies. The ruling supports state prosecutions when carriers refuse inspection under such state laws, and it lets states impose conditions on interstate liquor shipments in aid of enforcing local prohibition rules.