Commonwealth v. Lichter

1 Pa. D. & C. 709, 1922 Pa. Dist. & Cnty. Dec. LEXIS 129
CourtWashington County Court of Quarter Sessions
DecidedApril 17, 1922
DocketNo. 76
StatusPublished

This text of 1 Pa. D. & C. 709 (Commonwealth v. Lichter) is published on Counsel Stack Legal Research, covering Washington County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Lichter, 1 Pa. D. & C. 709, 1922 Pa. Dist. & Cnty. Dec. LEXIS 129 (Pa. Super. Ct. 1922).

Opinion

Brownson, P. J.,

The defendant was found guilty by a jury of the unlawful sale of whiskey. The indictment was based upon the Brooks Law, Act of May 13, 1887, P. L. 108, as amended by the Act of May 5, 1921, P. L. 407, commonly known as the Woner Act. We have before us a motion in arrest of judgment. The reasons assigned in support of it go in part to the form of the indictment. Matters of form are not a ground for arresting judgment upon an indictment duly found, after conviction by a jury, unless the defect of form amounts to a failure to charge an indictable offence. We are of opinion that this indictment charges with sufficient certainty what amounts to a criminal offence, provided the statute under which it was drawn is a valid piece of legislation. We, therefore, pass at once to [710]*710the grounds upon which the validity of that statute is attacked. It is contended that the act is inoperative because uncertain and incomplete in itself, and is unconstitutional and void because violative of several distinct provisions of the Constitution of Pennsylvania.

Before taking up these objections in detail, it will be useful to look at the historical background of the Woner Act and the purposes which the legislature sought to accomplish thereby.

Down until the time when the 18th Amendment of the Federal Constitution became operative, the Brooks Law regulated, by means of a license system, the retailing of vinous, spirituous, malt and brewed liquors, irrespective of their alcoholic content or their capability of producing intoxication in their ordinary use. That amendment prohibits, inter alia, the manufacture, sale or transportation of intoxicating liquors for beverage purposes within the United States. The Supreme Court of the United States decided in National Prohibition Cases, 253 U. S. 350, that this amendment operates directly upon and binds all legislative bodies, courts, public officers and individuals within the territorial limits of the United States, and that, by its own force and operation, it has had the effect of invalidating every legislative act, whether by Congress or by the legislature of a state or a territory, which authorizes or sanctions what the 1st section of the amendment prohibits. Accordingly, the instant the 18th Amendment became operative, the Brooks Law, in so far as it authorized the licensing, and the making when licensed, of sales of “intoxicating liquors,” became inoperative, though, in so far as it regulated and sanctioned the sale under licenses of alcoholic liquors that are not intoxicating, it continued in operation, unaffected by the amendment: Com. v. Vigliotti, 75 Pa. Superior Ct. 366, 271 Pa. 10; Cambria County Liquor Licenses, 78 Pa. Superior Ct. 28, 38-39.

After the adoption of the amendment, Congress, with the purpose of exercising the power, given to it by section 2, to legislate for the enforcement of national constitutional prohibition, passed the Volstead Act, which prohibited under penalties the manufacture, sale, etc., of any intoxicating liquor (with certain exceptions wherewith we are not concerned in the present case), and declared that the phrase “intoxicating liquor” should be construed as including, inter alia, all liquors containing one-half of 1 per centum of alcohol by volume and fit for use for beverage purposes. This enactment, the court declared in National Prohibition Cases, 253 U. S. 350, did not transcend the limits of the power of Congress to legislate for the enforcement of prohibition under the constitutional amendment. The majority of the court merely announced conclusions, without an opinion stating the reasons and grounds thereof, and there seems to have been some divergence of views as to what is the basis and ground of conclusion No. 11, to the effect that the act is valid, in so far as it treats liquors containing the percentage of alcohol mentioned, as within the power of prohibition by an enforcement law. Whether this conclusion is to be regarded as resting upon the view advanced by Chief Justice White in his concurring opinion, on page 391, that as the Constitution does not define the intoxicating beverages which it prohibits, the duty and function of defining them devolves upon Congress; or whether the view of the majority was (as their reference to the case of Ruppert v. Caffey, 251 U. S. 264, may tend to indicate) that as a means of effectually preventing the manufacture, sale, etc., of liquors that unquestionably are intoxicating, Congress has the right and power to class with them, and to prohibit under the same designation, other liquors which, although not in fact intoxicating as this term is commonly understood, yet contain, in a less degree, the same [711]*711toxic principle that is found in liquors that are so — in either event, it is a fact that the prohibition, in the Volstead Act, of beverages containing as much as one-half of 1 per cent, of alcohol has been determined by the court to be valid. And the court further declared (conclusion No. 9) that the power of Congress to legislate is territorially coextensive with the operation of section 1 of the amendment, embraces intrastate transactions, as well as importation, exportation and interstate traffic, and is in no wise dependent upon, or affected by, action or inaction on the part of the several states or any of them.

The result of all of this is that the Volstead Act, being a valid law passed by Congress in pursuance of the Constitution, is, by virtue of the 2nd section of article VI of the original Constitution, a part of the “supreme law of the land, . . . anything in the constitution or laws of any state to the contrary notwithstanding.” The sale of beverages containing one-half of 1 per centum of alcohol by volume is now forbidden by supreme and paramount national law, and, therefore, Pennsylvania, so long as the Volstead Act remains in force and unamended, cannot license the making of any such sales, though she may license the sale of liquors having a smaller alcoholic content: Com. v. Vigliotti, 271 Pa. 10. If, however, the national law should at any time be changed by substituting a different minimum alcoholic content, as, e. g., 1 per centum, the licensing power of Pennsylvania would correspondingly expand.

This was the situation by which the legislature was confronted, and with which it intended to deal, when it passed the Woner Act; and the design of this act was to cause national prohibition and Pennsylvania’s license system to fit into each other in such manner as that, together, they should occupy the entire field with respect to alcoholic liquors. The legislature desired to license the sale of such liquors to the extent that it has power to do so; to have the license system occupy the field up to the line where national prohibition begins and presents an obstacle to its further extension; and also, in case that obstacle should at any time by congressional action be moved back, thus placing within the control of the State a portion of the field now occupied by national prohibition, it wished to have the license system move up to the new line and occupy the additional ground thus thrown open to it. And, on the other hand, it was willing to co-operate with the national government for the enforcement of national prohibition.

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Related

Hanover National Bank v. Moyses
186 U.S. 181 (Supreme Court, 1902)
Jacob Ruppert v. Caffey
251 U.S. 264 (Supreme Court, 1920)
National Prohibition Cases
253 U.S. 350 (Supreme Court, 1920)
The People v. . Fire Association of Phil'A.
92 N.Y. 311 (New York Court of Appeals, 1883)
City of Wilkes-Barre v. Meyers
6 A. 110 (Supreme Court of Pennsylvania, 1886)
Commonwealth ex rel. Attorney General v. Mathues
210 Pa. 372 (Supreme Court of Pennsylvania, 1904)
Commonwealth v. Vigliotti
115 A. 20 (Supreme Court of Pennsylvania, 1921)
Commonwealth v. Dougherty
39 Pa. Super. 338 (Superior Court of Pennsylvania, 1909)
Commonwealth v. Sweeney
61 Pa. Super. 367 (Superior Court of Pennsylvania, 1915)
Commonwealth v. Vigliotti
75 Pa. Super. 366 (Superior Court of Pennsylvania, 1921)
Cambria County Liquor Licenses
78 Pa. Super. 28 (Superior Court of Pennsylvania, 1921)
State v. Parker
26 Vt. 357 (Supreme Court of Vermont, 1854)
Phœnix Insurance v. Welch
29 Kan. 672 (Supreme Court of Kansas, 1883)

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Bluebook (online)
1 Pa. D. & C. 709, 1922 Pa. Dist. & Cnty. Dec. LEXIS 129, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-lichter-paqtrsesswashin-1922.