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In the United States v. Sprague case of 1930, the Supreme Court ruled that Congress had the authority to regulate and prohibit alcohol under the Eighteenth Amendment without needing to provide for concurrent enforcement by states or individuals. The defendants, Sprague and others, were indicted for conspiracy to transport liquor into a dry state in violation of federal law. They argued that such laws could only be enforced by states or private citizens due to language within the amendment stating it should be "enforced...by appropriate legislation." However, their argument was rejected as they failed to demonstrate any constitutional requirement limiting enforcement power exclusively to states or individuals. The court held that this phrase did not limit Congress's ability but rather granted them broad discretion on how best to enforce prohibition.
In the dissenting opinion for United States v. Sprague et al., Justice Stone argued that the Seventh Amendment should apply to all cases, not just those tried in common law courts. He believed that this interpretation was more consistent with the intent of the framers and would better protect individual rights. He also disagreed with the majority's view on how constitutional amendments are ratified, arguing that they must be approved by state conventions rather than simply by state legislatures as had been done in this case. This disagreement stemmed from his belief that such a significant change to our system of government should require a higher level of consensus among states and their citizens.