United States v. Simpson

Background

A federal indictment charged a man with violating the Reed Amendment by transporting five quarts of whiskey from Cheyenne, Wyoming, into Denver, Colorado, in his own automobile for his personal use. Colorado prohibited the manufacture and sale of intoxicating liquor for beverage purposes. The district court sustained a demurrer to the indictment’s count and discharged the defendant, ruling the statute did not cover private personal transport.

Reasoning

The Supreme Court, in an opinion by Justice Van Devanter, reversed. It held the statute’s prohibition on causing intoxicating liquors to be transported into a prohibition state covers all modes of transportation, including a person driving their own automobile. The Court reasoned the law targeted the introduction of liquor into dry states — an evil Congress could regulate — and that the plain wording makes no carrier-based distinction; limiting the law to common carriers would invite easy evasion. The opinion relied on prior decisions treating such movement as interstate commerce and on lower federal courts that had applied the law to private automobile transport.

Real world impact

The practical result is that people can be prosecuted under the Reed Amendment for carrying liquor across state lines into a state that bans alcohol, even when the liquor is for personal use and transported in a private vehicle. The Court reversed the district court’s dismissal so the indictment could proceed.

Dissents or concurrances

Justice Clarke dissented, arguing interstate commerce properly refers to commercial trade and large-scale exchanges, not isolated private movements of personal property, and he believed the statute did not constitutionally reach this conduct.