Summary of Opinion: United States v. Lane Motor Co., No. 499 (Dec. 9, 1953)

Factual and Procedural Background

This case arose from a Government action in the District Court for the Eastern District of Oklahoma seeking forfeiture of an automobile and a truck under § 3116 of the Internal Revenue Code. Section 3116 authorizes seizure and forfeiture of property "intended for use in violating" the alcohol tax laws and property "which has been so used." The respondent claimed an interest in the two vehicles and contested the forfeitures.

The district court found that each vehicle had been used by the operator of an illegal distillery to drive several miles from his home and then to a point one-half mile or more from the distillery, at which point the operator walked the remaining distance; the Government had not proven that the vehicles were used to transport materials or utensils for the distillery. On that basis the district court ruled the facts did not justify forfeiture. The Court of Appeals for the Tenth Circuit affirmed that ruling (199 F.2d 495). The Government petitioned for certiorari, noting a conflict among the circuits (Third Circuit in United States v. One 1948 Plymouth Sedan, 198 F.2d 399, agreed with the Tenth Circuit; Sixth Circuit in United States v. One 1950 Ford Half-Ton Pickup Automobile Truck, 195 F.2d 857, took a contrary view). The Supreme Court granted certiorari to resolve the conflict and subsequently affirmed the judgment below.

Legal Issues Presented

Whether a vehicle used solely for commuting to an illegal distillery is "used in violating" the revenue laws within the meaning of § 3116 of the Internal Revenue Code and therefore forfeitable under that section.

Arguments of the Parties

Government's Arguments

The Government sought forfeiture of the automobile and truck under § 3116, alleging the vehicles were intended for use in violating the alcohol tax laws and had been used for that purpose.
The Government had alleged that the vehicles had been used to transport materials or utensils for use at the distillery (the district court found the Government had not shown this).

Respondent's Arguments

The respondent asserted an ownership interest in the two vehicles and contested the forfeitures.
The record shows the vehicles were used to transport the distillery operator from his home to a point some distance from the distillery, from which the operator proceeded on foot.

Table of Precedents Cited

Precedent	Rule or Principle Cited For	Application by the Court
199 F.2d 495	Affirmance of district court ruling that the facts did not justify forfeiture under § 3116.	The Supreme Court affirmed the judgment below, agreeing with the Tenth Circuit's result.
United States v. One 1948 Plymouth Sedan, 198 F.2d 399	Held in accord with the Tenth Circuit (interpretation consistent with non-forfeiture for commuting-only use).	Noted by the Court as a circuit decision in agreement with the Tenth Circuit; part of the circuit conflict prompting certiorari.
United States v. One 1950 Ford Half-Ton Pickup Automobile Truck, 195 F.2d 857	Expressed a contrary view in the Sixth Circuit regarding forfeiture under § 3116 for vehicle use.	Identified by the Court as the contrary authority that created a circuit conflict necessitating review.

Court's Reasoning and Analysis

The Court began with the statutory language of § 3116, which permits seizure and forfeiture of property "intended for use in violating" the alcohol tax laws and property "which has been so used." The district court found the vehicles had been used only to convey the distillery operator part of the way from his home to a point one-half mile or more from the distillery, with no proof that they had been used to transport materials or utensils to or from the distillery. The Court of Appeals for the Tenth Circuit affirmed that factual and legal determination. The Government sought certiorari because different Courts of Appeals had reached different conclusions on whether such commuting use constitutes use "in" violating the revenue laws. The Supreme Court granted certiorari to resolve this inter-circuit conflict and, based on the record and statutory language, concluded that a vehicle used solely for commuting to an illegal distillery is not used "in" violating the revenue laws within the meaning of § 3116.

Holding and Implications

Holding: Certiorari granted; the judgment of the Court of Appeals for the Tenth Circuit is affirmed.

Implications: As a direct result of the Court's decision in this case, the particular automobile and truck at issue were not forfeitable under § 3116 because they were used solely for commuting to the distillery. The opinion does not elaborate on broader consequences beyond the effect on the parties and the resolution of the cited circuit conflict.

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UNITED STATES v. LANE MOTOR CO.

A vehicle used solely for commuting to an illegal distillery is not used in violating the revenue laws within the meaning of § 3116 of the Internal Revenue Code and is not forfeitable thereunder. Pp. 630-631.

199 F.2d 495, affirmed.

PER CURIAM.

In this proceeding, the Government sought the forfeiture of an automobile and of a truck under the provisions of § 3116 of the Internal Revenue Code in the District Court for the Eastern District of Oklahoma. That Section allows the seizure and forfeiture of property "intended for use in violating" the alcohol tax laws, as well as property "which has been so used." The respondent, alleging an interest in the two vehicles, contested the forfeitures.

The district judge found the facts to be that the truck and automobile had each been used by the operator of an illegal distillery to drive a number of miles from his home and then parked at a point one-half mile or more from the distillery, the operator walking the rest of the way. The district judge found that the Government had not shown, as it had alleged, that the vehicles had been used for transporting materials or utensils for use at the distillery, and ruled that the facts shown did not justify a forfeiture. The Court of Appeals for the Tenth Circuit affirmed, 199 F.2d 495.

The Government has petitioned for a writ of certiorari showing that, while the Court of Appeals for the Third Circuit in United States v. One 1948 Plymouth Sedan, 198 F.2d 399 (1952), held in accord with the Tenth Circuit, the Court of Appeals for the Sixth Circuit has taken a contrary view, United States v. One 1950 Ford Half-Ton Pickup Automobile Truck, 195 F.2d 857 (1952). Certiorari is granted in order to resolve this conflict.

We think it clear that a vehicle used solely for commuting to an illegal distillery is not used in violating the revenue laws.

Certiorari granted, and the judgment affirmed.

UNITED STATES v. LANE MOTOR CO