Facts of the Case

The defendants in the case were arrested and convicted under an Act of Congress of 1895 that made it illegal to send or conspire to send lottery tickets across state lines.

Question

Did the transport of lottery tickets by independent carriers constitute "commerce" that Congress could regulate under the Commerce Clause?

Conclusion

In a 5-to-4 decision, the Court held that lottery tickets were indeed "subjects of traffic," and that independent carriers may be regulated under the Commerce Clause. The Court emphasized the broad discretion Congress enjoys in regulating commerce, noting that this power "is plenary, is complete in itself, and is subject to no limitations except such as may be found in the Constitution." The Court argued that Congress was merely assisting those states that wished to protect public morals by prohibiting lotteries within their borders.