In Re the Alcohol Beverage License Suspension of Cork 'N Bottle, Inc.

2002 SD 139, 654 N.W.2d 432, 2002 S.D. LEXIS 159
CourtSouth Dakota Supreme Court
DecidedNovember 20, 2002
DocketNone
StatusPublished
Cited by4 cases

This text of 2002 SD 139 (In Re the Alcohol Beverage License Suspension of Cork 'N Bottle, Inc.) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re the Alcohol Beverage License Suspension of Cork 'N Bottle, Inc., 2002 SD 139, 654 N.W.2d 432, 2002 S.D. LEXIS 159 (S.D. 2002).

Opinion

ZINTER, Justice.

[¶ 1.] The Cork ⅛ Bottle Inc. (CNB), a Yankton convenience store, sold alcohol to an underage purchaser, and its alcohol licenses were suspended by the Department of Revenue (Department). The circuit court affirmed the suspensions. CNB appeals arguing that it substantially complied with a “safe harbor” statute that precludes license suspension if the licensee utilized five precautionary measures to prevent underage alcohol sales. One of these precautionary measures required that the employee who sold the alcohol must have attended a “Department approved” training program. Because the licensee did not send the employee to “Department approved” training, we affirm the suspensions.

FACTS

[¶2.] Eugene Jensen owns the CNB. CNB holds a package liquor license and a retail beer license. As a part of this business, Jensen developed training and incentive programs that he designed to help prevent underage alcohol sales.

[¶ 3.] Under Jensen’s training and incentive programs, new employees were advised about the legal consequences of selling alcohol to underage purchasers. Jensen also attended a Tobacco Alcohol Management course, and he reviewed the course materials with each new employee. Additionally, employees were taught how to detect false identifications; employees were offered a $300 “bounty” for confiscation of the driver’s license of an underage person attempting to purchase alcohol; and, employees were required to sign an “Employee Liquor Liability Employment Agreement.” In the agreement, each employee indicated that they understood, and would follow, all laws regarding the sale of alcoholic beverages. Finally, some, but apparently not all employees attended a “Department approved” Tobacco Alcohol Management course that provided instruction on techniques to prevent underage sales of alcohol.

[¶ 4.] The events that precipitated this controversy began in November of 2000. At that time, CNB was notified by the Yankton County State’s Attorney that he would initiate a “sting” to ensure compliance with the laws prohibiting underage alcohol sales. This sting notice advised licensees that an undercover, underage person would attempt to illegally purchase alcoholic beverages from licensees in Yankton County. Jensen placed this “sting warning” in a location plainly visible to all employees. He also posted his notice of the “$300 cash [bounty] to whomever keeps the ID card.”

[¶ 5.] On December 8, 2000, Bonnie Dougherty’s fourth day of employment, she sold a six-pack of beer to an undercover, underage purchaser. Dougherty sold the beer even though she asked for the purchaser’s identification. Dougherty testified that she had a “mental lapse” and mistakenly checked the purchaser’s birth *434 date against the age required to purchase tobacco (age 18) rather than the age required to purchase alcohol (age 21).

[¶ 6.] Because of the illegal sale, the Department suspended CNB’s alcohol beverage licenses for two weeks pursuant to SDCL 35-2-10. 1 CNB appealed the Department’s decision to circuit court. In that appeal, CNB argued that it had substantially complied with a statute that provides a safe harbor for those licensees who take certain precautionary measures to prevent underage alcohol sales. The circuit court affirmed the Department’s suspension.

[¶ 7.] The sole issue on appeal is:

Whether CNB substantially complied with the “Department approved” employee-training requirement of the safe harbor statute.

STANDARD OF REVIEW

[¶ 8.] The facts in this case are not in dispute. The issue before us is a question of law. We review questions of law under the de novo standard. Paint Brush Corp. v. Neu, 1999 SD 120, ¶ 15, 599 N.W.2d 384, 389. Furthermore, liquor-licensing statutes are strictly construed against the licensee. Consolidated Municipality of Carson City v. Lepire, 112 Nev. 363, 914 P.2d 631, 633 (Nev.1996) (quoting West Indies v. First National Bank, 67 Nev. 13, 214 P.2d 144, 154 (Nev.1950)). As we noted in State v. Hy Vee Food Stores, Inc., 533 N.W.2d 147, 150 (S.D.1995), “[t]he serious problems associated with youth who abuse alcohol justify stringent enforcement against those who dispense it.” (emphasis added).

DECISION

[¶ 9.] The Secretary of Revenue is charged with administering the state’s alcoholic beverage laws. SDCL 35-1-2. Under those laws, the Secretary is authorized to revoke or suspend the license of any business that violates the prohibition against sales to underage purchasers. SDCL 35-2-10 and 35-2-21. Moreover, before those statutes were amended in 2000, the Secretary could suspend an alcohol beverage license without giving any consideration to the licensee’s efforts to prevent illegal sales or its previous record of underage sales. Id.

[¶ 10.] However, in 2000, the Legislature enacted SDCL 35-2-10.1. 2 That stat *435 ute provided licensees with a safe harbor from license suspension if the violation was committed by an employee or agent of the licensee and five requirements were satisfied. The second requirement (SDCL 35-2-10.1(2)) provides that the employee who made the illegal sale must have been certified by a nationally recognized “training program approved by the Department.”

[¶11.] This appeal arose because Dougherty did not attend a training program that was approved by the Department. Although there is no dispute about this fact, CNB argues that its own program ensured that its employees understood the law regarding underage alcohol sales. CNB also argues that its program provided sufficient instruction on techniques to prevent underage persons from purchasing or consuming alcoholic beverages. Consequently, CNB contends that, even though it did not strictly comply with SDCL 35-2-10.1(2), CNB is entitled to safe harbor because it substantially complied by providing its own equivalent training measures.

[¶ 12.] We recently addressed the doctrine of substantial compliance. We held that substantial compliance is not established unless the statute has been actually followed sufficiently to carry out the substance essential to eveiy reasonable objective of the statute. In making that determination, we noted that consideration should be given to the intent and purpose of the statute.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Estate of Smeenk
978 N.W.2d 383 (South Dakota Supreme Court, 2022)
In Re the Alcohol Beverage License Suspension of Engels
2004 SD 97 (South Dakota Supreme Court, 2004)
State v. Jensen
2003 SD 55 (South Dakota Supreme Court, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
2002 SD 139, 654 N.W.2d 432, 2002 S.D. LEXIS 159, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-alcohol-beverage-license-suspension-of-cork-n-bottle-inc-sd-2002.