Meserole v. Sutton

41 Pa. D. & C. 408, 1941 Pa. Dist. & Cnty. Dec. LEXIS 322
CourtPhiladelphia County Court of Quarter Sessions
DecidedApril 29, 1941
Docketno. 15
StatusPublished
Cited by1 cases

This text of 41 Pa. D. & C. 408 (Meserole v. Sutton) is published on Counsel Stack Legal Research, covering Philadelphia 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
Meserole v. Sutton, 41 Pa. D. & C. 408, 1941 Pa. Dist. & Cnty. Dec. LEXIS 322 (Pa. Super. Ct. 1941).

Opinion

Levinthal, J.,

This is a petition for the return of certain personal property confiscated by the police as illegal gambling devices.

The property in question consists of a punchboard and a box of Treasures Mints. The punchboard is trademarked “Punch-O-Free” and is described thereon as a “Sales Stimulator for Treasures Mint”. Lucky punches carry prizes ranging from 15^ to $15. Detailed instructions for the use of the board are attached thereto.

The following appears on the front:

“Presentation of Treasures Mint wrapper (or a reasonable facsimile thereof) entitles you to participate in ‘Punch-O-Free’ for prizes, absolutely free!

“Participation in this game does not depend upon any obligation on part of player.”

The “rules for playing” appear on the back of the board and they read:

“Each person presenting a wrapper of Treasures Mint (or a reasonable facsimile thereof) entitles you to participate on ‘Punch-O-Free’ for prizes.

“Purchasers and non-purchasers of Treasures Mints are privileged to ‘Punch-O-Free’ prizes.

“Punches are prohibited to minors.

“Storekeepers reserve the right to limit a participant to one puch [sic] on ‘Punch-O-Free’ daily.

“Please do not pay any money to participate on ‘Punch-O-Free’ for prizes. It is absolutely free.

“This ‘Punch-O-Free’ sales board is not to be used for gambling. (Please do not deviate from nor violate these rules.)

[410]*410“This possession of this ‘Punch-O-Free’ sales board and the use of it as set forth is absolutely legal when operated in accordance with these rules and regulations.

“There is no inducement.

“You do not have to participate, if you don’t want to.

“There is no consideration.

“It is absolutely free to everyone to participate.

“There is no chance taken.

“The award is our advertising money and expense.

“There is no gambling.

“You can’t lose anything you may win free.

“Every man or woman is eligible to participate in accordance with the rules and regulations.

“Storekeepers selling our mints are restricted to these rules and the Treasures Mint Company is not responsible for any violations of these rules.”

The confiscated punchboard was seized when found on display in a small candy store operated by one Samuel Fusia. A policeman testified that he purchased a roll of mints for five cents and was allowed to take a punch off the board. He won nothing. The punchboard and box of mints then were confiscated. The box contained a number of loose wrappers representing punches taken off the board but there were no facsimiles. According to Fusia, he received the board from petitioner, unaccompanied by any prize money. Should anyone have made a hit, he was to phone petitioner who would send the money immediately. A small prize of 20 cents had been won on this board but Fusia paid this from his own petty cash on hand.

It is unquestioned that the punchboard is a game of chance and that if valuable consideration is given for the opportunity to play the board it constitutes an unlawful gambling device subject to seizure and confiscation. It is urged, however, that here no such consideration is required inasmuch as the presentation of either a mint wrapper or a “reasonable facsimile” thereof entitles one [411]*411to participate. The validity of this contention is the sole issue for our determination.

Although the facts were somewhat different in Commonwealth v. Lund, 142 Pa. Superior Ct. 208 (1940), the rationale of that case constrains us to the conclusion that the issue must be resolved against petitioner. “Bank night” was involved in the Lund case, where a small number of “proxy” cards, entitling the holders to all the privileges of those present in the theatre at the time of the drawing, had been given away free. Apparently, anyone could secure these from the theatre owner or manager, although this feature was not advertised for fear that too many people would apply. In affirming a judgment of conviction for maintaining a lottery, the Superior Court adopted the opinion of President Judge Reader of the Beaver County court which contains an exhaustive discussion of the legality of the so-called “flexible participation lottery”. That opinion recognizes that in some States the possibility of participation in a lottery without contributing any valuable consideration therefor is held sufficient to remove the taint of illegality.

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Cite This Page — Counsel Stack

Bluebook (online)
41 Pa. D. & C. 408, 1941 Pa. Dist. & Cnty. Dec. LEXIS 322, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meserole-v-sutton-paqtrsessphilad-1941.