''United States v. Sprague'', 282 U.S. 716 (1931), was a
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case that dealt with the
Fifth Article of the US Constitution. The defendants had been indicted under the
National Prohibition Act and were attempting to quash their indictments, arguing that the
Eighteenth Amendment had not been properly ratified. Their reasoning was that the
Congress of the United States
The United States Congress is the legislature of the federal government of the United States. It is bicameral, composed of a lower body, the House of Representatives, and an upper body, the Senate. It meets in the U.S. Capitol in Wash ...
had chosen to ratify it by usage of
state legislatures instead of
constitutional conventions.
If this were held true, Congress would have exceeded its authority in passing the NPA. The court did not agree, however, ruling that the Constitution explicitly authorized Congress to determine the method used in ratifying amendments. In part, Article Five states that any amendment "shall be valid to all Intents and Purposes, as part of this Constitution, when ratified by the Legislatures of three-fourths of the several States, or by Conventions in three fourths thereof, ''as the one or the other Mode of Ratification may be proposed by the Congress''" (emphasis added).
Furthermore, the court rejected the defendants' claim that the Eighteenth Amendment needed to be ratified by state conventions since "all
revious amendmentssave the Eighteenth dealt solely with governmental means and machinery rather than with the rights of the individual citizen." The Constitution does not make a difference between types of amendments, the court held, so the amendment, "by lawful proposal and ratification, has become a part of the Constitution."
See also
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List of United States Supreme Court cases, volume 282
This is a list of cases reported in volume 282 of ''United States Reports'', decided by the Supreme Court of the United States in 1930 and 1931.
Justices of the Supreme Court at the time of volume 282 U.S.
The Supreme Court is establis ...
External links
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1931 in United States case law
United States Supreme Court cases
United States Supreme Court cases of the Hughes Court
United States Constitution Article Five case law
United States Eighteenth Amendment case law
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