Champion v. Ames
188 U.S. 321 (1903)
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Rule of Law:
The power of Congress to regulate commerce among the states includes the authority to prohibit the interstate shipment of articles, such as lottery tickets, that it deems harmful to the public welfare.
Facts:
- A Paraguayan lottery company issued tickets for a drawing with a large cash prize.
- Money to pay for the prizes was deposited in various banks within the United States.
- These lottery tickets were treated as items of value and were bought and sold in the market before the drawing.
- C. F. Champion arranged for the Wells Fargo Express Company, an independent carrier engaged in interstate transportation, to carry a box of these lottery tickets.
- The express company was tasked with transporting the tickets from Texas to California.
Procedural Posture:
- C. F. Champion was indicted in the United States Circuit Court for the Northern District of Texas for conspiracy to violate the Federal Lottery Act of 1895.
- Champion filed an application for a writ of habeas corpus in the Circuit Court of the United States for the Northern District of Illinois, arguing that the Act was unconstitutional and his detention was therefore unlawful.
- The Circuit Court denied Champion's application for the writ.
- Champion, as the appellant, appealed the Circuit Court's order directly to the Supreme Court of the United States.
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Issue:
Does the Federal Lottery Act of 1895, which prohibits the interstate carriage of lottery tickets, exceed Congress's power to regulate commerce among the states under the Commerce Clause of the Constitution?
Opinions:
Majority - Justice Harlan
No. The Federal Lottery Act is a constitutional exercise of Congress's power to regulate interstate commerce. The power to regulate commerce is plenary, complete, and subject only to limitations found in the Constitution itself. The Court reasoned that lottery tickets are subjects of traffic and therefore articles of commerce. Because they are articles of commerce, Congress has the power to regulate their movement between states. Furthermore, the power to regulate is not limited to prescribing rules for commerce but can also extend to outright prohibition, especially for articles that are considered a "widespread pestilence" and injurious to public morals. Congress may therefore use its commerce power to prevent interstate commerce from being used to spread what it deems a public evil, thereby protecting the people of all states.
Dissenting - Chief Justice Fuller
Yes. The Federal Lottery Act exceeds Congress's power under the Commerce Clause and infringes on powers reserved to the states. The dissent argued that the Act was not a regulation of commerce, but rather an attempt to exercise a general police power to suppress lotteries, a power that belongs to the states under the Tenth Amendment. It reasoned that lottery tickets are not articles of commerce; they are merely contracts or evidences of a chance, similar to insurance policies, which the Court had previously held not to be commerce. The dissent warned that if Congress could prohibit the transport of any item it disliked, it would effectively give Congress unlimited police power, destroying the distinction between state and federal authority and creating a centralized government contrary to the framers' intent.
Analysis:
This case, also known as The Lottery Case, is a landmark decision that significantly broadened the scope of Congress's authority under the Commerce Clause. It established for the first time that Congress could use its power to regulate interstate commerce as a de facto federal police power, allowing it to prohibit the movement of goods for moral or public welfare reasons. This precedent paved the way for subsequent federal legislation aimed at social reform, such as the Pure Food and Drug Act, the Mann Act, and even modern civil rights laws. The decision shifted the understanding of "regulation" to include prohibition, giving Congress a powerful tool to address national problems that cross state lines.
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