The Law School Authority

Champion v. Ames Case Brief

Summary of Champion v. Ames
Citation: 188 U.S. 321 (1903)

Relevant Facts: Congress passed a law banning the transportation of lottery tickets in interstate commerce, ostensibly relying on their constitutional authority to regulate commerce between the states. Petitioner Champion was arrested pursuant to a warrant for conspiracy to violate the lottery ticket trafficking statute. He then brought habeas proceedings against United States Marshall Ames, claiming that he was restrained of his liberty. The conspiracy warrant, executed in Chicago, was designed to compel his appearance in Texas where he was under indictment for violating the same federal law that made it illegal to transport lottery tickets through interstate commerce. In the underlying case, the government charged that Champion had conspired, and did in fact, attempt to ship lottery tickets from the Pan-American Lottery Company (based in Paraguay) from Texas to California. Champion, in his habeas petition, claimed that the law in question was void as it exceeded congressional authority to regulate interstate commerce.

Issue: Does Congress have authority, under the Commerce Clause, to regulate interstate transportation of lottery tickets, even where that regulation takes the form of an absolute prohibition?

Holding: Yes, lottery tickets are objects of commerce, and transporting them between states is undoubtedly commerce. Congress has plenary authority to regulate commerce, and their judgment will be upheld unless it conflicts with a specific constitutional limitation.

Reasoning: Justice Harlan delivered the opinion of the Court, opening with an explanation that the Constitution does not define “commerce” and thus the Court must endeavor to do so. Reciting the lengthy history of the Court’s Commerce Clause jurisprudence, Justice Harlan explained that commerce is navigation, intercourse, traffic, transit of persons, and transmission of messages. Congressional authority over commerce is plenary, and the Court is necessarily deferential; in other words, the Court will only strike down a congressional enactment premised on Commerce Clause authority if it is otherwise prohibited by the Constitution. The Court disagreed that the tickets themselves were of no value, and thus not commercial, concluding that the tickets were subjects of traffic and therefore commerce when they are carried by independent carriers. Next, the Court addressed contentions that the authority to regulate commerce does not encompass the authority to prohibit. The majority concluded that the broad commerce powers encompass all legitimate objects of regulation, and means appropriated for that purpose, including prohibition. Similarly, the Court disagreed that the Tenth Amendment limited Congressional authority to prohibit an entire class of goods. Citing other examples of regulation by prohibition, the Court concluded that the law in question represented Congressional judgment that prohibition was the only effective regulation. While the Court admitted that plenary power is not absolute power, and pointed out that such limitations could always be delineated in future cases, the only proper limitation on Commerce Clause authority is a conflicting constitutional provision. Otherwise, the majority explained, the Court risks substituting its own judgment for that of Congress, adding that the proper remedy for disagreeable (but not unconstitutional) congressional action lies in future elections.

Dissent: Chief Justice Fuller dissented, joined by Justices Brewer, Shiras, and Peckham. The dissenters concluded that lottery tickets were not objects of commerce, and did not transform into objects of commerce merely through shipment. Accordingly, the Congressional enactment at issue did not regulate commerce but instead sought to prohibit a disfavored behavior. Chief Justice Fuller explained that such a prohibition fit within police powers properly reserved to the states. Furthermore, the dissenters pointed out that both the authority to regulate foreign commerce and the authority to regulate commerce with Indian tribes are qualitatively different from the authority over interstate commerce, as the former two left no room for reservation of rights to the states. Concluding, Chief Justice Fuller explained that the majority holding here was inconsistent with the Framers’ intent when they conferred on Congress the authority to regulate interstate commerce.

Conclusion: Congress may regulate, and even prohibit, the transportation of lottery tickets in interstate commerce. Congress has plenary power over commerce, as may issue regulations as it sees fit unless otherwise prohibited by another constitutional provision.

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