United States v. Chambers

United States v. Chambers, 291 U.S. 217 (1934), was a United States Supreme Court case in which the court held that federal courts lost jurisdiction over National Prohibition Act prosecutions when the Eighteenth Amendment was repealed, so all proceedings either ongoing or on appeal were void.^[1][2]

Claude Chambers and Byrum Gibson were indicted in the District Court for the Middle District of North Carolina for conspiring to violate the National Prohibition Act, and for possessing and transporting intoxicating liquor contrary to that act, in Rockingham County in that State. The indictment was filed on June 5, 1933. Chambers pleaded guilty but prayer for judgment was continued until the December term.^[1]

On December 6, 1933, the case was called for trial as to Gibson. Chambers then filed a plea in abatement and Gibson filed a demurrer to the indictment, each upon the ground that the repeal of the Eighteenth Amendment to the United States Constitution deprived the court of jurisdiction to entertain further proceedings under the indictment. The District Judge sustained the contention and dismissed the indictment. The government appealed.^[1]

The Supreme Court issued an opinion on February 5, 1934.^[1] The Twenty-First Amendment did not contain any sort of "savings clause" that would have preserved the government's authority to complete prosecutions initiated under the auspices of the Eighteenth Amendment.^[2]

• Text of United States v. Chambers, 291 U.S. 217 (1934) is available from: Cornell Findlaw Justia

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain.