Champion v. Ames
Champion v. Ames, decided in 1903, addresses the scope of federal power to regulate interstate commerce, particularly in relation to public morality and safety. The case arose when C. F. Champion challenged the Federal Lottery Act of 1895, arguing that lottery tickets were not objects of commerce and that the federal government lacked the authority to prohibit them. The Supreme Court, in a 5-4 decision led by Justice John Marshall Harlan, concluded that lottery tickets do possess real value and qualify as items of commerce. The ruling established that Congress has the power not only to regulate commerce but also to prohibit products deemed harmful to society. This decision marked a significant expansion of federal authority, recognizing a de facto police power to safeguard public welfare, which aligned with Progressive ideals of the time. The implications of this ruling extended into other federal legislation, influencing laws related to public health and morality well into the 20th century, although its application remained restricted primarily to criminal activities. This case highlights the evolving interpretation of the commerce clause and its impact on legislative authority in addressing societal issues.
Champion v. Ames
Date: February 23, 1903
Citation: 188 U.S. 321
Issues: Definition of interstate commerce; federal police powers
Significance: In upholding a federal statute that prohibited the transportation of lottery tickets in interstate commerce, the Supreme Court defined commerce broadly and authorized the development of a federal police power.
Although the U.S. Constitution contains no federal police power, a broad interpretation of the commerce clause allowed the federal government to become involved with the public’s safety, health, morality, and welfare. In the late nineteenth century, Congress began to enact commerce-based police power legislation. For example, the Federal Lottery Act of 1895 had the goal of attacking gambling activities rather than regulating an object of commerce. When C. F. Champion was convicted of disobeying the statute, he asserted that the act was unconstitutional for three reasons: First, lottery tickets, as such, were not objects of commerce; second, even if they were objects of commerce, the word “regulate” in the commerce clause did not include the power to prohibit; and third, only the states, according to the Tenth Amendment, could exercise the police power.
Speaking for a 5-4 majority, Justice John Marshall Harlan emphasized the plenary nature of congressional power over interstate commerce. Lottery tickets were objects of real value and therefore items of commerce. The power to regulate commerce, moreover, encompassed the power to prohibit any products considered intrinsically harmful to the public. The effect of the so-called Lottery Case was to recognize that Congress might exercise a de facto police power, as desired by Progressives of the era. Based on the precedent, the Court upheld the Pure Food and Drug Act of 1906 in Hipolite Egg Co. v. United States (1911), and it upheld the Mann Act of 1910 (involving white slavery) in Hoke v. United States (1913). During this era, the Court’s acceptance of a federal police power was limited to regulation of criminal or “sinful” activities and did not extend to most economic regulations.