United States v. 422 Casks of Wine
|United States v. 422 Casks of Wine|
|Full case name||United States v. 422 Casks of Wine, Hazard & Williams Claimants|
|Citations||26 U.S. 547 (more)|
(1 Pet. 547, 7 L.Ed. 257)
|Prior history||The Sarah (1823)|
|Claimants in in rem cases must put claims under oath.|
|Judiciary Act of 1789|
United States v. 422 Casks of Wine 26 U.S. 547 (1 Pet. 547, 7 L.Ed. 257) is an 1828 Supreme Court of the United States civil forfeiture case between the United States against 422 casks of Malaga wine. The case was brought after the United States moved to seize the wine on the grounds it had been deliberately mislabeled as sherry to get a tax drawback, the buyers objected. The original trial found for the United States but was ordered to be retried after errors of jurisdiction were discovered. In the subsequent retrial, the Supreme Court ruled against the United States however they did grant them a certificate of seizure on probable cause.
The form of the styling of this case — the defendant being an object, rather than a legal person — is because this is a jurisdiction in rem (power over objects) case, rather than the more familiar in personam (over persons) case.
The 422 casks of Malaga wine were imported into the United States via New York State as a false entry before being moved to New Orleans, Louisiana. The wines were seized as it was viewed they had been deliberately mislabeled as sherry and were being used to falsely claim a tax drawback in 1819. The seizure was challenged by Messrs Hazard and Williams, whom were to purchase the wines from Charles Hall.
The case was first heard as "The Sarah", after the ship on which the wines were seized. During the proceedings at the District Court of Louisiana, it was revealed that the wines were seized on the land rather than on the seas so the United States moved for a jury trial, which the judge agreed to. The jury found for the United States with the judge issuing a sentence of condemnation against the wine. The appellants for the wines appealed to the Supreme Court arguing there had been irregularities in the proceedings as it had started as an Admiralty court case but then was treated as an Exchequer court case under the Judiciary Act of 1789 and so should not have been a jury trial. The District Attorney argued that there was nothing stopping an Admiralty court calling for a jury trial, citing the judices selecti of the Roman Empire. In 1823, the Supreme Court found that there were irregularities as when the court found the wine was seized on land, they should have stopped the trial as their jurisdiction had ended. As such, they annulled the seizure order and remitted the case back to the District Court for retrial.
Upon the District Attorney amending the complaint to an Exchequer case, the jury in this case found in favor of the wines. The Attorney-General of the United States appealed the decision to the Supreme Court on the grounds of asking for a Writ of Error in that Hall, the real owner, had not expressed opposition to the seizure. Hazard and Williams argued as the buyers, they had legal title to the wine. Justice Story delivered the verdict. He stated that because Hazard and Williams had proved they had a proprietary interest in the wine, they were legally entitled to challenge the seizure even if they were not the real owners. The court also held that while the mislabeling may have been fraudulent, it did not mean that the transfer of ownership was automatically void unless the claimants stated so. The court found there had been no error and affirmed the jury's decision in favor of the wine however it did grant the United States a certificate of probable cause of seizure as the cause for seizure affirmed in the original jury verdict had not been denied. The case was returned to the District Court to either return the wine to the claimants or proceed with the seizure under the certificate. The case is cited as Legal precedence for in rem cases where the claimant must put their claims on oath or the other party can insist on dismissal.
- "THE UNITED STATES v. 422 CASKS OF WINE, HAZARD & WILLIAMS CLAIMANTS". Cornell University. 2018-06-15. Retrieved 2019-01-11.
- "THE SARAH". Findlaw. 2016-03-31. Retrieved 2019-01-11.
- Cushing, Luther (1829). The American Jurist and Law Magazine. 1. Freeman & Bolles. p. 346. ISBN 9781330055724.