The White Court unanimously ruled in Dillon v. Gloss (1921) that Congress had the power to set time limits for ratification of a constitutional amendment by the states. The issue arose when defendant J. J. Dillon challenged his conviction for violating the National Prohibition Act by arguing that the Eighteenth Amendment, which gave Congress the power to pass the Prohibition Act, had not been ratified at the time of his alleged offense and arrest. The Court determined that Congress could set a time period for ratification of a constitutional amendment. With respect to defendant Dillon, it ruled his conviction valid because the Eighteenth Amendment was consummated on January 16, 1919, and Dillon was arrested a day later on January 17, 1919. “His alleged offense and his arrest were on the following day; so his claim that those provisions had not gone into effect at the time is not well-grounded,” White concluded.