United States v. Ryan, 284 U.S. 167 (1931)
U.S. Supreme CourtUnited States v. Ryan, 284 U.S. 167 (1931)
United States v. Ryan
Argued October 26, 27, 1931
Decided November 23, 1931
284 U.S. 167
1. Statutes designed to prevent fraud on the revenue are construed less narrowly, even though a forfeiture results, than penal statutes and others involving forfeitures. P. 284 U. S. 172.
2. In R.S. § 3453, which provides for forfeiture of (1) taxable articles found in the possession, custody, or control of any person for the purpose of being sold or removed by him in fraud of the internal revenue laws, (2) raw materials found in the possession of any person intending to manufacture the same into articles of a kind subject to tax, with intent to defraud the revenue, and (3) all tools, implements, instruments, and personal property whatsoever, in the
place or building, or within any yard or inclosure where such articles or raw materials are found, the phrase "such articles" in the third clause refers to the articles mentioned in both of the other clauses of the section, so that chattels associated with illicit possession, as well as those associated with illicit manufacture, are subject to forfeiture under the statute. P. 284 U. S. 173.
3. The uniform construction given to a statute by the lower federal courts for more than sixty years is persuasive in determining its true meaning. P. 284 U. S. 174.
4. In adopting § 3453 in the Revised Statutes without substantial change of the section as amended seven years previously, Congress must be deemed to have adopted the consistent interpretation theretofore given the amended section by the courts. P. 284 U. S. 175.
5. A literal application of a statute which would lead to absurd consequences is to be avoided whenever a reasonable application can be given which is consistent with the legislative purpose. Id.
6. The general words "all personal property whatsoever," as used in R.S. § 3453 to define what property is subject to forfeiture, must be construed, by application of the principle noscitur a sociis, to be limited in their meaning to chattels which have some relation to the tax evasion aimed at by the statute. P. 284 U. S. 176.
7. Bar fixtures and other saloon furnishings and equipment of a room in which tax unpaid intoxicating liquors were dispensed are subject to forfeiture under R.S. § 3453. Id.
8. A forfeiture under R.S. § 3453 of saloon furnishings and equipment seized in a place where tax unpaid liquor was possessed for sale is not barred by the arrest and prosecution of the offender under the National Prohibition Act. Id.
44 F.2d 951 reversed.
Certiorari, 283 U.S. 816, to review a judgment reversing a judgment for the Government in a forfeiture proceeding under R.S. § 3453.