Street v. Lincoln Safe Deposit Co.
Headline: Court permits owners to store lawfully acquired liquor in rented warehouse rooms for personal consumption, reversing lower court and blocking enforcement agents from seizing such stored liquor.
Holding: The Court held that storing lawfully acquired liquor in a rented warehouse room for personal use is not prohibited by the Volstead Act, and the district court's decree must be reversed.
- Stops seizure of lawfully acquired liquor stored in rented warehouse rooms under these admitted facts.
- Allows owners to keep and access stored bottles for personal consumption.
- Recognizes agency power to regulate transfers to prevent evasion.
Summary
Background
A man who had rented a room in the Lincoln Safe Deposit Company’s public warehouse had lawfully bought and stored wines and liquors there before the Volstead Act took effect. An agent of the Commissioner of Internal Revenue publicly threatened enforcement, and the warehouse told the owner to remove his liquor or it would hand the bottles to authorities. The owner sued for an injunction after a lower court dismissed his claim.
Reasoning
The Court addressed whether a storage company may lawfully keep liquor that was lawfully acquired before prohibition when the owner keeps exclusive control and intends the liquor only for personal consumption by himself, family, or bona fide guests. The justices examined Sections 3, 21, 25, and especially 33 of the Volstead Act. Section 33 exempts possession in a private dwelling for personal use; the Court found the admitted facts placed these bottles within that exemption except for the warehouse location. The Court concluded the warehouse’s limited custodial role — protecting the property and allowing the owner access — did not amount to the forbidden kinds of possession, delivery, or transportation described in the Act. Provisions aimed at places kept for sale did not apply, and Section 25 targets liquor intended for unlawful use. The Court therefore reversed the lower court’s dismissal.
Real world impact
The ruling prevents enforced seizure of lawfully acquired liquor stored under these facts and lets owners keep such bottles in rented warehouse rooms for personal use. It also recognizes administrative power to regulate transfers to prevent evasion.
Dissents or concurrances
Justice McReynolds agreed with the outcome but disagreed with the Court’s reasoning, warning enforcement could effectively confiscate private liquor.
Opinions in this case:
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