Corneli v. Moore

Background

A group of private buyers purchased identified barrels of whiskey that were stored in government bonded warehouses. The federal officials responsible for those warehouses were collectors of internal revenue. The buyers asked to pay taxes and have the barrels delivered to their homes for lawful use, but the collectors refused and the buyers sued in federal court. The lower courts dismissed their lawsuits, and the buyers appealed to the Supreme Court under the Eighteenth Amendment and the National Prohibition Act (Volstead Act).

Reasoning

The Court examined whether the Volstead Act allows owners to remove stored liquor from bonded warehouses to their private dwellings and whether refusing release violated the Fifth Amendment. The Court emphasized that the statute must be read broadly to prevent use of liquor as a beverage. It held that the Act's exceptions for liquor in a 'private dwelling' do not turn government bonded warehouses into parts of a home, and that provisions allowing storage or transfers to bonded warehouses do not permit removal to residences. The Court therefore affirmed the dismissals.

Real world impact

Owners who stored liquor in government bonded warehouses cannot force officials to release it for transport to private homes under the Volstead Act as interpreted here. Federal collectors may refuse release, and the decision upholds existing enforcement of Prohibition against such removals. The Court relied on earlier National Prohibition rulings.

Dissents or concurrances

Justice McReynolds dissented, arguing the decision conflicts with Street v. Lincoln Safe Deposit Co. and that bona fide owners lawfully storing liquor should be allowed to retrieve it for home use.