## Facts

- W. A. Vandercook Co., a California wine and brandy seller, shipped 68 packages from San Francisco to its agent in Charleston, South Carolina.
- Each package was consigned for delivery to a specific South Carolina customer who had ordered before shipment.
- While the liquor was held by a common carrier at a Charleston railroad depot, South Carolina officers (including Bahr and Scott) seized the packages under the state “Dispensary Law.”
- The complaint alleged the seizure and continued detention (including by officer Vance) were wrongful, malicious, and intended to interfere with the company’s interstate business.
- Vandercook sought return of the liquor or its value (alleged $1,000) and damages (alleged $10,000), claiming the Dispensary Law conflicted with the U.S. Constitution, chiefly the Commerce Clause.

## Issues

1. Whether South Carolina could, consistent with the Commerce Clause, enforce its Dispensary Law by seizing intoxicating liquors shipped from another state while the goods were at the destination depot for delivery to named purchasers.
2. Whether a state may, under its police power, monopolize liquor distribution and subject imported liquor to that system upon arrival without unlawfully burdening interstate commerce.
3. Whether Vandercook could recover the liquor (or its value) and damages from state officers on the theory that the Dispensary Law was unconstitutional as applied.

## Decision

- The Supreme Court reversed the federal judgment for Vandercook.
- The Court sustained the Dispensary Law’s application to the seized shipments, concluding the officers’ enforcement did not amount to unconstitutional interference with interstate commerce.
- The Court rejected the claim that a state liquor monopoly is per se invalid under the Commerce Clause where the scheme operates without discrimination against out-of-state products.

## Legal Principles

- Intoxicating liquors are subject to extensive state police power regulation, including restrictive distribution systems and state monopolies.
- The Commerce Clause bars state laws that discriminate against out-of-state products or directly burden interstate commerce as such, but does not bar nondiscriminatory liquor regulation applied after arrival within the state.
- For Commerce Clause purposes, a state may regulate the in-state sale and distribution of imported liquor once the goods have arrived and are subject to the state’s internal regulatory system.
- Congressional policy (as reflected in federal liquor legislation recognized by the Court) permits states, upon arrival of shipments, to subject imported liquor to the same regulatory treatment as domestic liquor.
- When the underlying statute is constitutional as applied, state officers enforcing it are not liable for damages on the theory that they violated federally protected commerce rights.

## Conclusion

The Court held that South Carolina could enforce a nondiscriminatory state-controlled liquor distribution system against imported liquor after arrival in the state, so the seizure and detention of Vandercook’s shipments did not violate the Commerce Clause and did not support recovery against the enforcing officers.


Vance v. W. A. Vandercook Co., 170 U.S. 468 (1898)