Opinion: 291 U.S. 217 (1934)

HOLDING: The defendant’s conviction for violating Prohibition laws before Prohibition’s repeal was vacated because the Twenty-First Amendment to the Constitution had repealed Congress’s power under the Eighteenth Amendment to prohibit the sale of alcoholic beverages.

The Eighteenth Amendment came into effect in 1920.  The amendment gave Congress the power to prohibit the manufacture, sale, or transportation of alcoholic beverages within the United States.  Congress used that power to pass the Volstead Act.  But the Eighteenth Amendment was repealed when the states ratified the Twenty-First Amendment on December 5, 1933.  

On June 5, 1933, six months before the end of Prohibition, Clause Chambers and Byrum Gibson were charged with violating the Volstead Act in the District Court.  Their cases were called for trial December 6, 1933, the day after the Twenty-First Amendment was ratified.  Chambers and Gibson moved to dismiss the charges on the ground that the Twenty-First Amendment eliminated the authority Congress had used to pass the Volstead Act.

The Supreme Court held that the Twenty-First Amendment’s ratification immediately rendered the Eighteenth Amendment inoperative.  Consequently, “[n]either the Congress nor the courts could give it continued vitality.”  The Twenty-First Amendment also nullified provisions of the Volstead Act that rested upon Congress’s Eighteenth Amendment powers, including provisions that imposed criminal sanctions for violations of the Act.  So courts were required to dismiss all pending prosecutions for Volstead Act violations, including proceedings on appeal, for lack of jurisdiction.