The Lambert v. Yellowley case in 1926 revolved around the interpretation of the Volstead Act, which provided for enforcement of the Eighteenth Amendment to prohibit intoxicating beverages. Dr. Lambert argued that limiting his prescription of alcohol to a patient was an infringement on his rights as a physician and violated due process under the Fifth Amendment. The Supreme Court disagreed with this argument, ruling that Congress had broad power to regulate medical practice in relation to its authority over interstate commerce and public health matters. Therefore, it upheld restrictions placed by federal law on physicians prescribing spirits for therapeutic purposes during Prohibition.

In the dissenting opinion for Lambert v. Yellowley, Justice Oliver Wendell Holmes Jr. argued that the majority's interpretation of the Eighteenth Amendment and Volstead Act was too broad and infringed upon individual liberties. He contended that while Congress had the power to regulate alcohol consumption as it pertained to intoxication, it did not have authority over personal use in moderate quantities for health purposes as prescribed by a physician. In his view, such regulation constituted an invasion of personal liberty protected under the Fifth Amendment’s Due Process Clause. Furthermore, he disagreed with equating any amount of alcohol consumption with intoxication or its potential harm on public welfare or morals; instead asserting that only excessive drinking could be reasonably linked to these concerns.