Thursday, November 14, 2013

Champion v. Ames case brief

Champion v. Ames case brief summary
188 U.S. 321 (1903) Lottery Case

Appeal from a Circuit Court of the United States for the Northern District of Illinois decision that dismissed appellant's writ of habeas corpus after holding that the Federal Anti-Lottery Act, 28 Stat. 963 (1895) was not a restraint of liberty in violation of the United States Constitution.

Congress enacted the Federal Lottery Act of 1895 (FLA) which prohibited the buying and selling of lottery tickets across state lines. Charles Champion (defendant) was indicted by U.S. Marshall Ames (plaintiff) for bringing Paraguayan lottery tickets into the United States and shipping them from Texas to California in violation of the FLA. Champion challenged his indictment by alleging that Congress’s Commerce Clause power does not include the power to completely prohibit a certain kind of commerce; only to regulate it. Champion brought this challenge in a writ of habeas corpus in the Circuit Court for the Northern District of Illinois, which dismissed the case. Champion appealed to the United States Supreme Court.

Appellant challenged the constitutionality of the Federal Anti-Lottery Act (Act), 28 Stat. 963 (1895), after he was charged with conspiracy to violate the Act by carrying lottery tickets from one state to another using a freight company. The lower court denied appellant's writ of habeas corpus, holding that the Act was not a restraint on appellant's liberties.


  • On appeal, the Court affirmed and held that lottery tickets were subjects of traffic among those who trade in them and thus, that the carriage of such tickets by independent carriers from one state to another involved interstate commerce. 
  • The Court also held that such carriage was subject to regulation by Congress under the Commerce Clause of the United States Constitution. 
  • Since the Commerce Clause granted Congress plenary authority over interstate commerce, it was within Congress' power to invoke the Act and prohibit carriage of such tickets among states.
The lower court's decision was affirmed. Since lottery tickets were subjects of interstate commerce, it was within Congress' plenary power to enact the Federal Anti-Lottery Act (Act), and appellant was properly prohibited under the Act from using a freight company to transport the tickets from state to state.

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