United States v. Sprague
1931 U.S. LEXIS 39, 282 U.S. 716, 51 S. Ct. 220 (1931)
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Rule of Law:
Article V of the Constitution grants Congress the sole and exclusive discretion to choose the method of ratification for proposed constitutional amendments, either by state legislatures or by state conventions, without regard to the subject matter of the amendment.
Facts:
- The U.S. Congress proposed the Eighteenth Amendment, which prohibited the manufacture, sale, or transportation of intoxicating liquors.
- In its proposal, Congress stipulated that the amendment should be ratified by the state legislatures.
- The requisite three-fourths of the state legislatures ratified the Eighteenth Amendment, and it was declared part of the Constitution.
- Congress subsequently passed the National Prohibition Act to enforce the amendment.
- William H. Sprague and his co-appellees were found to be unlawfully transporting and possessing intoxicating liquors.
Procedural Posture:
- The appellees were charged by indictment in a U.S. District Court with violating the National Prohibition Act.
- The appellees filed a motion to quash the indictment, arguing that the Eighteenth Amendment was not constitutionally ratified because it should have been submitted to state conventions instead of state legislatures.
- The District Court granted the motion and quashed the indictment, holding that the Eighteenth Amendment was not validly ratified.
- The United States, as the prosecutor, appealed the District Court's order directly to the Supreme Court of the United States.
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Issue:
Does Article V of the Constitution grant Congress the exclusive and unrestricted authority to choose between ratification by state legislatures or by state conventions for a proposed amendment, even when the amendment grants new powers to the federal government over individual liberties?
Opinions:
Majority - Mr. Justice Roberts
Yes. Article V gives Congress the sole discretion to choose the mode of ratification for a constitutional amendment. The text of Article V is unambiguous, providing two clear methods of ratification—by legislatures or by conventions—and explicitly states that the choice of method is 'as the one or the other mode of ratification may be proposed by the Congress.' The court reasoned that the Constitution was written in plain language to be understood by voters, and where the text is clear, there is no room for judicial construction or interpolation. Arguments that amendments affecting personal liberties require ratification by conventions, based on the framers' intent for ratifying the original Constitution, are rejected because the framers could have easily included such a limitation in Article V but did not. Furthermore, the Tenth Amendment does not reserve this power to the people, as Article V is a direct grant of authority from the people to Congress to function as their agent in the amendment process.
Analysis:
This decision solidifies the principle of textualism in constitutional interpretation, emphasizing that the plain meaning of the text controls when it is unambiguous. It establishes that the choice of ratification method under Article V is a 'political question' left exclusively to the discretion of Congress, thereby precluding judicial review of that choice based on the amendment's substance. By rejecting the argument that different types of amendments require different ratification methods, the Court reinforced a uniform and predictable amendment process, strengthening congressional authority over constitutional change.
