Module 31: The Eighteenth Amendment

Why Prohibition Reached the Constitution

For most of the nineteenth century the question of alcohol belonged to the states. Some banned sales, some licensed saloons, and many let counties decide. By 1916, 23 of the 48 states had laws against saloons.¹ The Anti-Saloon League, founded in 1893, began a state-by-state campaign in 1906 and became the best-organized single-issue lobby of its day.¹

The campaign changed course when state laws proved hard to hold. A dry state could be supplied by mail and rail from a wet one. National law solved that problem. It would also be the first time the Constitution was amended to regulate what ordinary adults could make and sell, a reach the Court had to explain in the cases below.

This lesson follows the amendment in order: the text; the votes in Congress; the ratification record, including Idaho's January 1919 vote; the questions the Supreme Court settled in 1920 to 1922; the Volstead Act; how enforcement reshaped search and seizure law; the repeal by the Twenty-first Amendment; and Idaho's own liquor laws. The one-sentence summary for local officials is this: the amendment banned the trade and left possession and drinking unaddressed, and its repeal returned most of the power to the states.

The Text, Section by Section

After one year from the ratification of this article the manufacture, sale, or transportation of intoxicating liquors within, the importation thereof into, or the exportation thereof from the United States and all territory subject to the jurisdiction thereof for beverage purposes is hereby prohibited.

U.S. Const. amend. XVIII, sec. 1²

The Congress and the several States shall have concurrent power to enforce this article by appropriate legislation.

U.S. Const. amend. XVIII, sec. 2²

Section 1: what was banned

Three activities were named: manufacture, sale and transportation of intoxicating liquors for beverage purposes. Importing into and exporting from the United States were added. The text does not mention buying, owning or drinking. The amendment was to take effect one year after ratification.

Section 2: who enforces

Enforcement was shared. "Concurrent power" meant that Congress and each state could pass enforcement laws, a feature that produced the double-prosecution question in United States v. Lanza.³

Section 3: the deadline

The third section required ratification by state legislatures within seven years of submission. This made the Eighteenth the first amendment to carry a ratification deadline.¹ The Court's later decision in Dillon v. Gloss upheld the idea.⁴

Passage in Congress, 1917

The Senate passed the resolution 65 to 20 on August 1, 1917, with Democrats voting 36 to 12 and Republicans 29 to 8 in favor. The House followed on December 17, 1917 by 282 to 128. The Senate agreed to the House's changes 47 to 8 the next day, December 18, 1917, which the National Archives gives as the date of congressional passage.¹²

The vote was bipartisan and the majority crossed regional lines. Both houses cleared the constitutional bar of two-thirds, which the Court later said means two-thirds of the members present, assuming a quorum.⁵ The numbers above come from a secondary source, and this lesson did not open the Congressional Record to check them.

Ratification, 1918 to 1919

Mississippi ratified first, on January 7, 1918. The pace picked up in January 1919, when most legislatures were in session. Idaho ratified on January 8, 1919, the 19th state by the order on the Wikipedia list. Nebraska was the 36th, on January 16, 1919, completing the three-fourths needed. New Jersey ratified in 1922 as the 46th state. Connecticut and Rhode Island never did.⁶

The date on which the amendment took effect was settled by the Supreme Court. The Secretary of State certified the ratification on January 29, 1919, but the Court held in Dillon v. Gloss that the amendment became part of the Constitution on January 16, 1919, when the 36th legislature acted.⁴ From there the one-year clock ran, and nationwide prohibition began on January 17, 1920.⁶⁷

From the congressional vote on December 18, 1917 to Nebraska's ratification on January 16, 1919 was 394 days. The Senate Historical Office puts it at 13 months.⁷

Challenges to Ratification, 1920 to 1921

Opponents brought suits in several states. The Supreme Court answered them together in 1920, and again in a case about the time limit in 1921.

Hawke v. Smith (June 1, 1920)

The Ohio constitution gave voters the right to approve or reject laws passed by the legislature by referendum. Ohio's General Assembly ratified the Eighteenth Amendment, and a petition sought to put that ratification to a vote. The Court held that this could not be done. The state referendum provisions were "inconsistent with the Constitution of the United States," because "ratification by a State of a constitutional amendment is not an act of legislation within the proper sense of the word. It is but the expression of the assent of the State to a proposed amendment."⁸ Article V names the legislature or a convention as the ratifying body. A state cannot add a step of its own.

The National Prohibition Cases (June 7, 1920)

One week later the Court announced its conclusions in a group of cases brought by states and by liquor interests. The Court held that the amendment fell within Article V, that two-thirds of a quorum suffices for proposal, that referendum provisions cannot apply to ratification, and that the amendment was valid and operative throughout the United States. On section 2, the Court said "concurrent power" did not mean joint power. The section lets Congress and the states enforce the prohibition by appropriate means and gives neither the power to defeat it.⁵⁹

Dillon v. Gloss (May 16, 1921)

A man held for violating the Volstead Act argued that the amendment's seven-year ratification period was an unconstitutional addition to Article V. The Court disagreed. "Congress, in proposing an amendment, may fix a reasonable time for ratification," and seven years was reasonable.⁴ The decision set the rule that later amendments with a deadline relied on.

The Volstead Act

Congress defined the amendment's terms in the National Prohibition Act of 1919, called the Volstead Act after its House sponsor, Representative Andrew Volstead of Minnesota. The Senate Historical Office reports that the head of the Anti-Saloon League drafted it. President Wilson vetoed it, and the Senate voted 65 to 20 on October 28, 1919 to override the veto.⁷

The act defined "intoxicating" liquor as anything with more than 0.5 percent alcohol, a limit that covered most beer and wine. Canada's limit, by comparison, was 2.5 percent.⁷ The Senate Historical Office says the act "left the states no room for local option or any other flexibility." The Supreme Court in the National Prohibition Cases held that the 0.5 percent limit was within the enforcement power.⁷⁹

Concurrent Power and Double Prosecution

Because Congress and the states could each enforce the amendment, a person could break both laws with one act. United States v. Lanza (1922) answered whether the second prosecution was barred by the Fifth Amendment's double jeopardy clause. Chief Justice Taft wrote for the Court that "an act denounced as a crime by both national and state sovereignties is an offense against the peace and dignity of both and may be punished by each."³ The Fifth Amendment limits only the federal government in a single proceeding, and a state prosecution and a federal prosecution are separate proceedings.

This lesson did not trace how the rule has developed since 1922, so check current authority before relying on it for a modern case.

Enforcement and the Fourth Amendment

The Fourth Amendment protects people against unreasonable searches and seizures. Prohibition enforcement tested it in two ways.

Cars: Carroll v. United States (1925)

Federal officers stopped a car about sixteen miles east of Grand Rapids, Michigan, searched it, and found 68 bottles behind the upholstering of the seats. The Court held that officers may search a vehicle for contraband without a warrant "if made upon probable cause, i. e., upon a belief, reasonably arising out of circumstances known to the officer, that the vehicle contains such contraband liquor." The reason was practical: with a vehicle, "it is not practicable to secure a warrant because the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought."¹⁰ The automobile exception grew from this case.

Wiretaps: Olmstead v. United States (1928)

Federal agents tapped the telephone lines of a large bootlegging operation, from the basement of an office building and from public streets, with no physical trespass on the defendants' property. By 5 to 4 the Court held that the evidence did not violate the Fourth Amendment.¹¹ Justice Holmes wrote in dissent that he agreed with Justice Brandeis's examination of the case.¹¹

The rule lasted 39 years. In Katz v. United States (1967) the Court held that "the 'trespass' doctrine there enunciated can no longer be regarded as controlling," and the Fourth Amendment protects people, whatever the physical location of a tap.¹² Officers who monitor calls, and reporters who cover them, work under Katz.

Repeal: The Twenty-first Amendment

Congress proposed repeal on February 20, 1933. Ratification came on December 5, 1933, when Utah became the 36th state, acting by a convention vote of 20 to 0.¹³¹⁴ The Twenty-first is the only amendment ratified by state conventions instead of legislatures. Idaho's convention acted on October 17, 1933, making Idaho the 27th state to ratify.¹⁴ This lesson did not find Idaho's convention vote count.

The repeal amendment has three sections. Section 1 repealed the Eighteenth. Section 2 reads that transportation or importation of liquor into any State "in violation of the laws thereof" remains prohibited, which gave each state a constitutional basis for its own liquor rules.¹³ Section 3 required ratification by conventions within seven years.

Prohibition under the amendment lasted from January 17, 1920 to December 5, 1933, a span of 5,071 days.⁶¹³ State and local liquor law, including dry counties, continued afterward. Mississippi, the last state to end statewide prohibition, did so in 1966.¹⁴

What the Amendment Did Not Do

The text bars manufacture, sale and transportation, and says nothing of possession, purchase or consumption. Wikipedia notes the amendment "did not outlaw possession or consumption."¹ The Volstead Act and state laws filled some of the gap, but the amendment itself did not.

The amendment also did not stop states from going further. Idaho had banned possession for personal use in prohibition districts in 1915, and the Supreme Court upheld that rule in Crane v. Campbell, decided before the amendment was even proposed to the states.¹⁵¹⁶

Quick Questions and Answers

How many states did it take, and when was the 36th?

Thirty-six of 48. Nebraska was the 36th, on January 16, 1919.⁶

When did the amendment become part of the Constitution?

The Court held it was January 16, 1919, not the January 29 certification.⁴

Could a state vote on ratification by referendum?

No. Hawke v. Smith held that the Constitution assigns ratification to legislatures or conventions.⁸

Could a person be prosecuted by both a state and the United States?

Yes, under Lanza.³

Landmark Cases

Each case below was checked against the opinion text where a link appears in the footnotes. Supporting cases appear in the sections above.

The Idaho Connection

Idaho goes dry before the nation

Idaho adopted county local option in 1909, according to a secondary compilation of newspaper columns.¹⁸ In February 1915 the legislature passed a statewide prohibition law, chapter 11 of the 1915 session laws, approved February 18, 1915. It makes it unlawful in a prohibition district to sell, manufacture, dispose of, possess or transport intoxicating liquor except under a permit. The penalty was a fine of $50 to $500 and 30 days to 6 months in jail, and a second offense was a felony punishable by 1 to 2 years at hard labor. Section 22 barred possession for any use without a permit.¹⁶ The same legislature refunded license fees for licenses that would expire after January 1, 1916.¹⁶

Ed Crane was arrested in Latah County on May 16, 1915 for possessing a bottle of whiskey for his own use. The Idaho Supreme Court rejected his habeas petition, and the U.S. Supreme Court affirmed on December 10, 1917, holding that a state "has power absolutely to prohibit manufacture, gift, purchase, sale, or transportation of intoxicating liquors within its borders."¹⁵

A constitutional ban, 1916

The 1915 legislature also proposed an amendment to the Idaho Constitution, new article III, section 26, which would forbid the manufacture, sale, keeping for sale and transportation for sale of intoxicating liquors for beverage purposes "from and after the first day of May in the year 1917."¹⁹ Voters ratified it on November 7, 1916, as Amendment No. 23.¹⁷ A newspaper column reports the vote as "about three to one."¹⁸

Idaho ratifies the Eighteenth Amendment, January 1919

Idaho ratified by House Joint Resolution No. 1 of the 1919 session. It passed the House on January 7, 1919 and the Senate on January 8, 1919.²⁰ Idaho was the 19th state by the order on Wikipedia's list.⁶ Not confirmed: the roll-call tallies in each house.

Enforcement under state law

A 1921 Idaho act, chapter 30, provided for forfeiture of vehicles and animals used to carry liquor in violation of state law.²¹ A secondary source reports a 1928 enforcement summary of 703 arrests, 86 stills destroyed, 7,750 gallons of liquor and 30,020 gallons of mash destroyed, and 25 automobiles confiscated.¹⁸

Repeal in Idaho

Idaho's convention ratified the Twenty-first Amendment on October 17, 1933, the 27th state.¹⁴ The Idaho Constitution was then amended. Amendment No. 39, ratified by voters November 6, 1934, replaced section 26 with a grant of "full power and authority to permit, control and regulate or prohibit" the manufacture, sale, keeping for sale and transportation for sale of intoxicating liquors from December 31, 1934.¹⁷

Idaho liquor law today

Idaho Code Title 23 builds on that grant. Section 23-201 sets up the State Liquor Division (added in 1939). Section 23-901 states the policy of state liquor stores plus licensing (added in 1947). Section 23-903 has the Director of the Idaho State Police issue licenses, one for each 1,500 residents of a city.²² Chapter 13 allows counties to decide on table wine, and chapter 10 covers beer, though this lesson did not read those chapters.²²

Not confirmed: Idaho's convention vote count in 1933; the roll calls on ratification in 1919; the current text of every Title 23 provision beyond those named above.

Where This Shows Up for Officials, Reporters and Citizens

The city clerk and the license quota

The clerk of an invented Idaho city is asked why a second license is unavailable. Idaho Code section 23-903 ties licenses to city population at one for each 1,500 residents. The policy in section 23-901 explains that Idaho regulates sales through state stores and licensing. The clerk can point to those sections and to Art. III, section 26 as the source of the legislature's authority.²²¹⁷

The county commissioner and the dry-county question

A resident of an invented county asks whether the county can ban wine sales. The state's constitution gives the power to "permit, control and regulate or prohibit" to the legislature. Chapter 13 of Title 23 is where to read the county option, and the answer depends on its text, which this lesson did not read.¹⁷²²

The reporter and the date question

A reporter writes that Prohibition began on January 16, 1919. That is the date the amendment became part of the Constitution, and nationwide prohibition began a year later, on January 17, 1920. A correct report gives both dates.⁴⁷

The reporter and the search story

A reporter covering an invented traffic stop is told the officers needed a warrant. Carroll and the later automobile cases say a vehicle can be searched without one on probable cause. For phone calls, Katz replaced the trespass rule of Olmstead. The court order, if any, and the department's policy are the places to check.¹⁰¹²

Related Modules

Related lessons: Amending the Constitution (Article V, including the seven-year deadline); Federalism and the States (the state-federal division of power); The Fourth through Eighth Amendments (search and seizure, double jeopardy); The Sixteenth Amendment (the other amendment of the Progressive era); The Nineteenth Amendment (ratified the year Prohibition began); and The Twenty-first Amendment (the repeal).

Sources & Further Reading

Primary Sources

• National Archives: Amendments 11-27 (text of the Eighteenth and Twenty-first Amendments)
• Senate Historical Office: The Volstead Act
• Crane v. Campbell, 245 U.S. 304 (1917), govinfo
• Hawke v. Smith, 253 U.S. 221 (1920), govinfo
• National Prohibition Cases, 253 U.S. 350 (1920), govinfo
• Dillon v. Gloss, 256 U.S. 368 (1921), govinfo
• United States v. Lanza, 260 U.S. 377 (1922), govinfo
• Carroll v. United States, 267 U.S. 132 (1925), govinfo
• Olmstead v. United States, 277 U.S. 438 (1928), govinfo
• Katz v. United States, 389 U.S. 347 (1967), govinfo

Secondary Sources and Further Reading

• Wikipedia: Eighteenth Amendment (secondary)
• Wikipedia: Twenty-first Amendment (secondary)
• American History and Genealogy Project: Idaho Prohibition (secondary)

Idaho Law and Records

• Idaho Session Laws 1915 (Internet Archive)
• Idaho Session Laws 1919 (Internet Archive)
• Idaho Session Laws 1921 (Internet Archive)
• Idaho Constitution and amendment table (Secretary of State)
• Idaho Code Title 23 (Idaho Legislature)

Related Training Modules

• Amending the Constitution
• Federalism and the States
• The Fourth through Eighth Amendments
• The Sixteenth Amendment
• The Nineteenth Amendment
• The Twenty-first Amendment

Footnotes

1. Eighteenth Amendment to the United States Constitution (Wikipedia, secondary source, read October 2026): the Senate passed the resolution 65 to 20 on August 1, 1917 and the House 282 to 128 on December 17, 1917; the Senate agreed to the House changes 47 to 8 on December 18, 1917; the Anti-Saloon League was founded in 1893 and began a state-by-state campaign in 1906; by 1916, 23 of the 48 states had laws against saloons; the amendment was the first to carry a ratification deadline; and it did not outlaw possession or consumption. Wikipedia is a secondary source. The vote counts should be confirmed in the Congressional Record, which this lesson did not open.
2. U.S. National Archives, The Constitution: Amendments 11-27 (Amendment XVIII: "Passed by Congress December 18, 1917. Ratified January 16, 1919. Repealed by amendment 21."). The three sections quoted in this lesson are from that transcription.
3. United States v. Lanza, 260 U.S. 377 (decided December 11, 1922), official text (govinfo) (Taft, C.J.): "an act denounced as a crime by both national and state sovereignties is an offense against the peace and dignity of both and may be punished by each." The Court reversed an order of the District Court for the Western District of Washington that had set aside a federal indictment after a state conviction for the same acts.
4. Dillon v. Gloss, 256 U.S. 368 (decided May 16, 1921), official text (govinfo) (Van Devanter, J.). The syllabus records that "Congress, in proposing an amendment, may fix a reasonable time for ratification"; that "the period of seven years, fixed by Congress in the resolution proposing the Eighteenth Amendment, was reasonable"; and that the amendment "became a part of the Constitution on January 16, 1919, when, as the court notices judicially, its ratification in the state legislatures was consummated; not on January 29, 1919, when the ratification was proclaimed by the Secretary of State."
5. National Prohibition Cases (State of Rhode Island v. Palmer and companion cases), 253 U.S. 350 (decided June 7, 1920), official text (govinfo). Van Devanter, J., "announced the conclusions of the court." The syllabus records that the amendment "establishing a fundamental rule of law, is an amendment within the meaning of Article V"; that the two-thirds vote required to propose an amendment "is a vote of two-thirds of the members present assuming the presence of a quorum"; that referendum provisions of state constitutions cannot be applied to ratification; and that the second section's words "concurrent power" "do not mean joint power" and do not enable Congress or the states "to defeat or thwart the prohibition, but only to enforce it by appropriate means."
6. Eighteenth Amendment to the United States Constitution (Wikipedia), ratification list: Mississippi January 7, 1918 (first); Ohio and Oklahoma January 7, 1919; Idaho and Maine January 8, 1919; Nebraska January 16, 1919 (the 36th, with the Secretary of State's certification on January 29, 1919 by acting Secretary Frank L. Polk); New Jersey March 9, 1922 (the last of 46). Connecticut and Rhode Island rejected. The state-by-state dates are from this secondary list and were not checked against each legislature's journal.
7. U.S. Senate, Senate Historical Office, "The Volstead Act": the Senate voted 65 to 20 on October 28, 1919 to override President Wilson's veto; the act set a limit of 0.5 percent alcohol, where Canada's was 2.5 percent; the head of the Anti-Saloon League drafted it and Representative Andrew Volstead sponsored it; and the amendment was ratified by the states within 13 months.
8. Hawke v. Smith (No. 1), 253 U.S. 221 (decided June 1, 1920), official text (govinfo) (Day, J.). The syllabus holds that the action of the Ohio General Assembly ratifying the Eighteenth Amendment "cannot be referred to the electors of the State, the provisions of the state constitution requiring such a referendum being inconsistent with the Constitution of the United States." The opinion states that "ratification by a State of a constitutional amendment is not an act of legislation within the proper sense of the word. It is but the expression of the assent of the State to a proposed amendment." George S. Hawke is listed on the brief for the plaintiff in error; Ohio's Secretary of State was the defendant.
9. National Prohibition Cases, 253 U.S. at 386-387, the numbered conclusions: (1) the amendment is within the amending power; (2) the two-thirds vote means two-thirds of members present; (3) a proposal need not carry an express declaration of necessity; (4) referendum provisions cannot apply to ratification; (5) the amendment is valid; (6) section 1 is operative throughout the United States; (7) "concurrent power" in section 2 does not defeat the prohibition. The list is condensed from the syllabus and the closing pages of the report; read the report for the exact wording.
10. Carroll v. United States, 267 U.S. 132 (decided March 2, 1925), official text (govinfo) (Taft, C.J.). The syllabus records that searches of vehicles for contraband liquor "do not violate the Amendment, if made upon probable cause, i. e., upon a belief, reasonably arising out of circumstances known to the officer, that the vehicle contains such contraband liquor." The opinion distinguishes a search of a building, for which a warrant ordinarily can be obtained, from a search of "a ship, motor boat, wagon or automobile, for contraband goods, where it is not practicable to secure a warrant because the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought." Justices McReynolds and Sutherland dissented.
11. Olmstead v. United States, 277 U.S. 438 (decided June 4, 1928), official text (govinfo). Taft, C.J., delivered the opinion of the Court. The syllabus holds that where taps were made "in the basement of a large office building and on public streets, and no trespass was committed upon any property of the defendants," obtaining and using the evidence "did not violate the Fourth Amendment." The Court granted review limited to that single question. The vote of 5 to 4, with Justices Holmes, Brandeis, Butler and Stone dissenting, is taken from the reporter's listing of the separate opinions and should be confirmed in the report.
12. Katz v. United States, 389 U.S. 347, 353 (decided December 18, 1967), official text (govinfo): "the underpinnings of Olmstead and Goldman have been so eroded by our subsequent decisions that the 'trespass' doctrine there enunciated can no longer be regarded as controlling."
13. U.S. National Archives, The Constitution: Amendments 11-27 (Amendment XXI: "Passed by Congress February 20, 1933. Ratified December 5, 1933."). Section 1 repeals the Eighteenth Amendment; section 2 prohibits the transportation or importation of intoxicating liquors into any State "in violation of the laws thereof"; section 3 requires ratification by conventions in the several States within seven years.
14. Twenty-first Amendment to the United States Constitution (Wikipedia, secondary source, read October 2026): ratification by state conventions; Minnesota October 10, 1933; Idaho 27th on October 17, 1933; Maryland October 18; Utah the 36th on December 5, 1933 by a vote of 20 to 0; South Carolina's convention rejected on December 4, 1933; Mississippi was the last state to end statewide prohibition (1966). Idaho's convention vote count was not found.
15. Crane v. Campbell, 245 U.S. 304 (decided December 10, 1917), official text (govinfo) (McReynolds, J.). Ed Crane was held on a charge of possessing "a bottle of whiskey for his own use and benefit" in Latah County, Idaho, "a prohibition district," on May 16, 1915; the Idaho Supreme Court had quashed his writ of habeas corpus (In re Crane, 27 Idaho 671). The Court held that "a State has power absolutely to prohibit manufacture, gift, purchase, sale, or transportation of intoxicating liquors within its borders without violating the guarantees of the Fourteenth Amendment." Campbell was the sheriff. Wayne B. Wheeler is listed on the brief for the defendant in error.
16. Idaho Session Laws, 1915 (Thirteenth Session), chapter 11 (Senate Bill No. 50, approved February 18, 1915), pp. 41 ff., Internet Archive full text. Section 2 makes it unlawful in a prohibition district to sell, manufacture, dispose of, possess or transport intoxicating liquor except under a permit; section 18 sets a fine of $50 to $500 and jail of 30 days to 6 months; section 19 makes a second offense a felony punishable by 1 to 2 years at hard labor; section 22 bars possession for any use without a permit.
17. Idaho Secretary of State, Idaho Constitution with the table of amendments. Amendment No. 23 added article III, section 26 (S.J.R. 1, ratified by the voters November 7, 1916). Amendment No. 39 replaced it (1933 S.J.R. 5, S.L. p. 470, ratified November 6, 1934). The current section reads: "From and after the thirty-first day of December in the year 1934, the legislature of the state of Idaho shall have full power and authority to permit, control and regulate or prohibit the manufacture, sale, keeping for sale, and transportation for sale, of intoxicating liquors for beverage purposes."
18. Idaho Prohibition, American History and Genealogy Project (transcribed newspaper columns and a quotation from the Cyclopedia of Temperance; a secondary compilation): county local option in 1909; the statutory prohibition law passed in February 1915 and effective January 1, 1916; the November 7, 1916 vote for the constitutional amendment "by about three to one," effective May 1, 1917; and a 1928 enforcement summary of 703 arrests, 86 stills, 7,750 gallons of liquor and 30,020 gallons of mash destroyed, and 25 automobiles confiscated. These figures are from secondary newspaper text and are not independently confirmed.
19. Idaho Session Laws, 1915, Senate Joint Resolution No. 1 (S.L. p. 395), Internet Archive full text, proposing a new article III, section 26: "From and after the first day of May in the year 1917, the manufacture, sale, keeping for sale, and transportation for sale of intoxicating liquors for beverage purposes are forever prohibited. The legislature shall enforce this Section by all needful legislation." The resolution passed the Senate on January 20, 1915 and the House on January 21, 1915.
20. Idaho Session Laws, 1919 (Fifteenth Session), House Joint Resolution No. 1, pp. 617-618, Internet Archive full text: the resolution recites the amendment and ends "Passed the House January 7, 1919. Passed the Senate January 8, 1919." The recital of section 2 reads "That Congress and the several States," a slight variance from the National Archives text. The roll-call tallies were not found.
21. Idaho Session Laws, 1921, chapter 30 (Senate Bill No. 86), pp. 38-39 (approved February 23, 1921), Internet Archive full text: forfeiture of vehicles and animals used to transport liquor in violation of Idaho law.
22. Idaho Code, Title 23, Idaho Legislature. Section 23-201 (State Liquor Division, added 1939); section 23-901 (policy declaration, added 1947, providing for state liquor stores and for licensing); section 23-903 (license issued by the Director of the Idaho State Police, one license per 1,500 residents of a city). Chapter 10 (beer) and chapter 13 (County Option Kitchen and Table Wine Act) were identified by title only and their text was not read.