Dillon v. Gloss

Background

A man was jailed under the National Prohibition Act after being charged with transporting intoxicating liquor. He filed a petition asking to be released, arguing that the Eighteenth Amendment was invalid because Congress had said the amendment must be ratified within seven years, and arguing that the Prohibition rules were not yet in effect at the time of his alleged offense and arrest. A lower court denied his petition, and he appealed to the Supreme Court.

Reasoning

The Court addressed whether Congress may set a time limit for ratifying a proposed amendment and whether the seven‑year period made the Eighteenth Amendment invalid. The Court examined Article V and the history of past amendments, concluded that ratification must occur within a reasonable time, and held that Congress may fix a definite period. It found seven years reasonable here. The Court also noted that the Amendment was ratified on January 16, 1919, that it took effect one year later, and that the Secretary of State’s later proclamation did not change that date. Because the offense and arrest occurred the day after January 16, 1920, the petitioner’s claim failed.

Real world impact

The decision lets federal Prohibition rules be enforced from January 16, 1920, and makes similar timing challenges less likely to succeed. It confirms that Congress can set reasonable deadlines for amendment ratification, and that the effective date of an amendment is the date of its ratification, not the date of a later proclamation. The ruling also makes clear that the Secretary of State’s later proclamation date does not change the amendment’s effective date.