There is no conflict and the state law is valid. The Court erected a distinction between manufacture and commerce. The state law regulated manufacturing only. A broad view of commerce that embraces manufacturing would also embrace the power to regulate "every branch of human industry."
Lamar, joined by Miller, Field, Bradley, Harlan, Matthews, Gray, Blatchford
Fuller took no part in the consideration or decision of the case.
Kidd v. Pearson, 128 U.S. 1 (1888), was a case in which theSupreme Court of the United States held that a distinction between manufacturing and commerce meant that anIowa law that prohibited the manufacture of alcohol (in this case for sale out-of-state) was constitutional as it did not conflict with the power of theUS Congress to regulateinterstate commerce.
In 1882, Iowa became adry state with a passage of a state constitutional amendment. An Iowa state law supporting that prohibition made the manufacturing of liquor in Iowa illegal unless it was for mechanical, medicinal, culinary, and sacramental purposes. Nonetheless, thePolk County Board of Supervisors granted J. S. Kidd a license to operate a distillery in 1884 for other uses based on his intent to only sell the liquor outside the state of Iowa. When the state moved to close the distillery as apublic nuisance, Kidd sued and argued it was outside of state jurisdiction as an exclusively interstate business under thecommerce clause.
The court ruled that there was not a conflict between Congress' power to regulate interstate commerce and the state law covering manufacturing within a given state. Therefore, the law was valid.[1]
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