Following the decision of the United States Supreme Court that the Wilson Act did not affect interstate shipments of liquor until final delivery by the carrier, Rhodes v. Iowa, 170 U. S. 412, (898), Congress passed the Webb-Kenyon Act, 37 Stat. at L. 699 (1913). Meantime, in 1913, 35 Stat. at L. 1136, Sec. 239, it was enacted that it should be a penal offense for any carier or other agent, in connection with the interstate carriage of intoxicating liquors, to collect the purchase price from the consignee, or in any manner act as agent of buyer or seller, except in the actual transportation or delivery thereof. After this act carriers and banks refused to act as collection agents in such sales, and dealers resorted to the plan of consigning liquor which had been ordered from prohibition states, to their own order, mailing the bill of lading to an agent, with instructions to deliver the same upon payment of the accompanying draft by the purchaser. In Danciger v. Cooley, U. S. Supreme Court, Adv. 0. 139, Jan. 7, i919, it was held that this was ih violation of Sec. 239, supra, and of course illegal. The shipment was made before 1913, and so did not involve the Webb-Kenyon Act.
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