108oag3

CourtMaryland Attorney General Reports
DecidedMarch 16, 2023
Docket108oag3
StatusPublished

This text of 108oag3 (108oag3) is published on Counsel Stack Legal Research, covering Maryland Attorney General Reports primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
108oag3, (Md. 2023).

Opinion

ALCOHOLIC BEVERAGES

STATUTORY INTERPRETATION – HEALTH – FOOD SERVICE FACILITIES – WINERIES – WHETHER THE HOLDER OF A CLASS 4 LIMITED WINERY LICENSE CAN PREPARE CERTAIN LIMITED FOODS FOR SALE OR SERVICE AT THE WINERY

March 14, 2023 Edward C. Rothstein, President Board of Carroll County Commissioners

Since the repeal of Prohibition in 1933, Maryland has had a detailed scheme of laws that regulate the manufacture, distribution, and sale of alcohol in the State. See 1933 Md. Laws, Spec. Sess., ch. 2; see also U.S. Const., Amend. XXI (repealing the 18th amendment and recognizing state regulation of alcohol). That scheme, broadly speaking, establishes a “three tier” system that distinguishes alcohol manufacturers from wholesalers, and wholesalers from alcohol retailers. See Department of Legis. Servs., Regulation of the Alcoholic Beverages Industry in Maryland 13 (2017) (“Regulation of Alcohol”). Licenses for manufacturers and wholesalers are issued by the State’s Alcohol and Tobacco Commission (“ATC”), while retail licenses are issued by the local boards of license commissioners in the counties and Baltimore City. Regulation of Alcohol, supra, at 13; see also 99 Opinions of the Attorney General 31, 32 (2014).1

You have asked for an opinion of the Attorney General regarding the scope of one type of manufacturer’s license—the Alcoholic Beverages Article. Among other things, that provision

1 These sources and others written before 2021 indicate that the State Comptroller is responsible for licensing and regulating alcohol manufacturers and wholesalers. In 2019, the Legislature passed a law creating the Alcohol and Tobacco Commission, see 2019 Md. Laws, ch. 12, which, as of 2021, is tasked with issuing manufacturing and wholesaling licenses, and generally enforcing and regulating the State’s alcohol laws, see Comptroller of Maryland, “Maryland Alcohol [and] Tobacco Commission,” https://www.marylandtaxes.gov/divisions/atc/index.php (noting that, “[e]ffective January 1, 2021,” the ATC became “authorized to enforce and regulate the state’s laws concerning alcoholic beverages”) (last visited Mar. 8, 2023). The Comptroller continues to have authority over alcohol taxes. See Alcohol & Tobacco Tax Joint Annual Report by the Alcohol and Tobacco Commission & Comptroller of Maryland 1 (2021). 3 4 [108 Op. Att’y

permits a licensee to “sell or serve” only limited types of foods— including, for example, baked goods, cured meats, fruits, and pizza. Md. Code Ann., Alc. Bev. (“AB”) § 2-206(b)(5)(iii). You ask whether this subsection allows the license holder to prepare the listed foods on the winery premises for sale or service at the winery or whether the license holder is instead limited to selling or serving food prepared elsewhere. As explained below, we conclude that nothing in AB § 2-206 precludes a limited winery license holder from preparing the foods enumerated in that section on the premises of the winery. But the license holder must still comply with any applicable food service licensing requirements authorized under the Health-General Article.

I Background

A. Winemaking & Class 4 Limited Winery Licenses

State law regulating the manufacture, distribution, and sale of alcohol is located in the Alcoholic Beverages Article. Division I of that article contains general and statewide provisions. See, e.g., AB § 1-405 (precluding issuance of licenses for premises unless the premises conform with certain tax requirements and zoning laws, regulations, or ordinances); id. §§ 2-201 through 2-219 (laws related to manufacturer’s licenses). Division II contains the provisions relevant to local jurisdictions, including all of the counties, Baltimore City, and Annapolis. In addition to authorizing specific alcohol retail licenses for each local jurisdiction, see, e.g., id. § 16-803 (Class B beer and wine license in Carroll County), the provisions in Division II also authorize jurisdiction-specific exemptions from some of the general provisions in Division I, or tailor those general provisions in certain ways,2 see id. § 1-202(b) (“A provision in Division II of this article prevails over a conflicting or inconsistent provision in Division I of this article or

2 Notably, while the General Assembly has, through laws enacted in Division II of the Alcoholic Beverages Article, added variations to Class 4 limited winery licenses issued under § 2-206 in certain jurisdictions, there is no local jurisdiction in which that class of manufacturing license is entirely inapplicable. See, e.g., AB §§ 16-401(c)(1), 16-403 (providing that the Class 4 limited winery license applies in Carroll County, and that a license holder that applies for a Class A wine license is exempt from certain license population quota limitations); § 25-407(b) (providing that, in Montgomery County, the “restrictions under § 2- 206(b)(5)(iii), (6)(ii)”—the food service provisions—“do not apply to a [Class B-BWL (clubhouse/lodge)] license issued under this subsection”). Gen. 3] 5

a provision in the Tax-General Article relating to alcoholic beverages.”); compare, e.g., id. § 2-208 (providing, in Division I, for a Class 6 Pub-Brewery License), with id. § 9-401(b) (providing, in Division II, that a Class 6 Pub-Brewery License does not apply in Allegany County). We focus here, of course, on the provisions governing limited winery licenses that are codified in AB § 2-206.

The General Assembly first created the Class 4 limited winery license in 1951. See 1951 Md. Laws, ch. 276. That law, among other things, made changes to the ordinary “three tier” system to allow the holder of a rectifying, winery, or brewery license to apply for and obtain a wholesaler’s license. Id. By 1973, the Legislature appeared to recognize that, in addition to operating as manufacturers and wholesalers of alcohol, wineries occupied space in the State’s agricultural and tourism industries as well. Thus, the General Assembly amended the Class 4 limited winery license provision so that wineries could engage in, to some extent, the activities of all three tiers of Maryland’s system of alcohol regulation—manufacturing, wholesaling, and retailing.3 See 1973 Md. Laws, ch. 593 (allowing holders of Class 4 limited winery licenses to “sell wine made from products grown in Maryland at a retail price at the plant to persons participating in a guided tour of the facility”); see also Regulation of Alcohol, supra, at 7 (noting that “[i]n the last several decades, economic forces have prompted manufacturers, wholesalers, and retailers to expand their scope of operations, causing a partial melding of the three tier system”). In light of these laws, one historian of Maryland wine has suggested that “wineries don’t easily fit into th[e] three-tier system, as they are a unique business model that happens to be a manufacturer, a wholesaler and quite often a retailer of its own product.” Regina McCarthy, Maryland Wine: A Full-Bodied History 87 (2012).

Maryland had nine wineries by 1984, McCarthy, supra, at 65, and throughout the 1990s and early 2000s, the industry continued to grow, id. at 68, 72. In 2004, the Secretary of Agriculture appointed the Maryland Wine and Grape Advisory Committee (“Wine & Grape Committee”) to “investigate the Maryland wine industry and learn how to promote its growth.” Id. at 89. The Wine 3 In some instances, a manufacturer may need additional alcoholic beverage licenses in order to act as a wholesaler or retailer. See, e.g., AB § 2-307 (providing for Class 6 limited wine wholesalers’ licenses, which holders of Class 4 limited winery licenses may obtain). However, “[e]xcept as provided in Subtitle 3”—the subtitle governing wholesalers’ licenses—“a [Class 4 limited winery] license holder need not obtain any other license to possess, manufacture, sell, or transport wine or pomace brandy.” Id. § 2-206(b)(4).

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