ckage of liquors introduced
from another State.[929] The effect of the latter decision was soon
overcome by an act of Congress, the so-called Wilson Act, repealing its
alleged silence,[930] but the Bowman decision still stood, the act in
question being interpreted by the Court not to subject liquors from
sister States to local authority until their arrival in the hands of the
person to whom consigned.[931] Not till 1913 was the effect of the
decision in the Bowman case fully nullified by the Webb-Kenyon Act,[932]
which placed intoxicants entering a State from another State under the
control of the former for all purposes whatsoever.

OLEOMARGARINE AND CIGARETTES

Long before this the immunity temporarily conferred by the original
package doctrine upon liquors had been extended to cigarettes[933] and,
with an instructive exception, to oleomargarine. The exception referred
to was made in Plumley _v._ Massachusetts,[934] where the Court held
that a statute of that State forbidding the sale of oleomargarine
colored to look like butter could validly be applied to oleomargarine
brought from another State and still in the original package. The
justification of the statute to the Court's mind was that it sought "to
suppress false pretenses and promote fair dealing in the sale of an
article of food." Nor did Leisy and Co. _v._ Hardin[935] apply, said
Justice Harlan for the Court, because the beer in that case was "genuine
beer, and not a liquid or drink colored artificially so as to cause it
to look like beer." That decision was never intended, he continued, to
hold that "a State is powerless to prevent the sale of articles
manufactured in or brought from another State, and subjects of traffic
and commerce, if their sale may cheat the people into purchasing
something they do not intend to buy * * *."[936] Obviously, the argument
was conclusive only on the assumption that a State has a better right to
prevent frauds than it has to prevent drunkenness and like evils; and
doubtless that is the way the Court felt about the matter at that date.
On the one hand, the liquor traffic was a very ancient, if not an
altogether, venerable institution, while oleomargarine was then a
relatively novel article of commerce whose wholesomeness was suspect. On
the other hand, laws designed to secure fair dealing and condemnatory of
fraud followed closely the track of the common law, while anti-liquor
laws most decidedly did not. The real differe