## Facts

- Dillon was held in federal custody under the National Prohibition Act for allegedly transporting intoxicating liquor.
- He sought habeas corpus relief, challenging the legality of his custody.
- Dillon argued the Eighteenth Amendment was invalid because Congress conditioned its effectiveness on ratification within seven years.
- He also argued that, even if valid, the Eighteenth Amendment and the relevant enforcement provisions were not yet in effect when he was arrested on January 17, 1920.
- The district court denied habeas relief, and Dillon appealed directly to the Supreme Court.

## Issues

1. Whether Article V permits Congress, when proposing a constitutional amendment, to require ratification within a fixed and reasonable period (here, seven years).
2. When the Eighteenth Amendment became part of the Constitution and, as a result, when the relevant enforcement provisions of the National Prohibition Act became effective.

## Decision

- The Supreme Court affirmed the denial of habeas relief.
- Article V implies ratification must occur within a reasonable time after proposal; Congress may set that reasonable period in the proposing resolution.
- A seven-year ratification deadline was reasonable.
- The Eighteenth Amendment became part of the Constitution when the requisite number of states ratified it (January 16, 1919), not when federal officials later proclaimed ratification.
- Because the Amendment provided it would take effect one year after ratification, it became effective on January 16, 1920.
- The National Prohibition Act provisions tied to the Amendment’s effective date were in force by January 16, 1920; Dillon’s arrest the next day was under valid law.

## Legal Principles

- Article V contemplates that proposal and ratification must be sufficiently contemporaneous; ratification is not open indefinitely.
- Congress may condition a proposed amendment on ratification within a reasonable time by including a deadline in the proposing resolution.
- A seven-year deadline for ratification is constitutionally permissible as a reasonable period.
- An amendment becomes part of the Constitution upon completion of ratification by the required number of states; subsequent official proclamation does not determine the constitutional date of adoption.
- When an amendment specifies an effective date keyed to ratification, statutes triggered by that effective date may take effect accordingly.

## Conclusion

The Court upheld Congress’s authority to impose a reasonable ratification deadline in proposing a constitutional amendment and held that the Eighteenth Amendment was adopted upon completion of state ratification and effective one year later, making the Prohibition enforcement provisions applicable to Dillon’s conduct and custody.


Dillon v. Gloss, 256 U.S. 368 (1921)