United States v. Hill

1919-01-13
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Headline: Interstate alcohol transport limited: Court upholds 1917 federal law banning carrying liquor into states that prohibit its sale, making it illegal to bring alcohol across state lines into dry states.

Holding:

Real World Impact:
  • Makes it illegal to carry alcohol into dry states even for personal use.
  • Expands federal authority to regulate interstate movement of goods, including personal luggage.
  • Allows federal prosecutions when state bans on sale exist in the destination state.
Topics: interstate transport, alcohol laws, state prohibition, federal regulation

Summary

Background

A man named Dan Hill bought one quart of intoxicating liquor in Kentucky, boarded a trolley that crossed into West Virginia, and was indicted under the 1917 Reed Amendment for bringing alcohol into a State that outlawed its sale and manufacture. The District Court sustained a demurrer and motion to quash the indictment, treating the law as aimed only at commercial shipments rather than personal carriage.

Reasoning

The Supreme Court considered whether the Reed Amendment covers moving liquor in interstate travel for personal use. The Court explained that "interstate commerce" includes transporting people and their goods across state lines, and that the statute unambiguously forbids ordering, purchasing, or transporting intoxicating liquor into a State that bans its sale, except for narrow listed purposes. Relying on earlier federal laws and the national commerce power, the Court held the statute constitutional as applied and reversed the District Court.

Real world impact

The ruling means people who carry alcohol from one State into another that prohibits sale or manufacture can be prosecuted under the federal law, even when the alcohol is for personal use. The decision affirms that federal regulation of interstate movement can override state choices about alcohol when Congress legislates on the subject.

Dissents or concurrances

Justice McReynolds dissented, arguing the law improperly interfered with a State’s internal policy and exceeded federal power; Justice Clarke joined that dissent.

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