The Fuller Court ruled 8–0 in Kidd v. Pearson (1888) that the state of Iowa could ban the manufacture and sale of “intoxicating liquors” unless the alcohol is used for “mechanical, medicinal, culinary or sacramental purposes.” A distillery owned by J. S. Kidd challenged the constitutionality of the statute, arguing that it infringed on the powers of the U.S. Congress, which regulates interstate commerce. The distillery argued that the banning of the manufacturing of liquor negatively impacted interstate commerce because it limited the flow of alcohol to other states.

The Fuller Court rejected this argument, finding that the statute affected in-state manufacturing, not interstate commerce. The Court explained that the state’s broad police powers enabled it to control the manufacture and sale of alcohol. With respect to the interstate commerce argument, it explained: “It does not follow that, because the products of a domestic manufacture may ultimately become the subjects of interstate commerce, at the pleasure of the manufacturer the legislation of the state respecting such manufacture is an attempted exercise of the power to regulate commerce exclusively conferred upon congress.”