Crane v. Campbell

Background

A man was arrested in Latah County, Idaho, on May 16, 1915, for having a bottle of whiskey for his own use inside a local prohibition district. Idaho’s 1915 law made it unlawful to possess, sell, manufacture, or transport intoxicating liquors in such districts except under narrow permits; the State Supreme Court reviewed a habeas corpus challenge and rejected the claim that the law violated the Fourteenth Amendment.

Reasoning

The U.S. Supreme Court considered whether the statute’s ban on mere possession of whiskey for personal use violated the Fourteenth Amendment’s protections of privileges, life, liberty, or property. The Court relied on earlier decisions recognizing a State’s broad power to prohibit manufacture, sale, and transport of intoxicating liquors and said measures reasonably necessary to make such prohibition effective are permissible. The Court found the possession ban was not arbitrary or unrelated to the State’s public health, morals, and safety goals, and concluded that holding liquor for personal use is not a fundamental federal privilege protected from state regulation.

Real world impact

The ruling upholds convictions and detentions based solely on private possession of alcohol inside Idaho’s prohibition districts and affirms that States may adopt strict rules to suppress liquor traffic. Because this decision enforces the statute as written, people living or passing through local prohibition zones face criminal liability for possessing whiskey, and enforcement discretion rests with state and local authorities.