George Weston Anderson

In Scaffidi v. United States, defendants Leonard Scaffidi and Michael Daddona were convicted by a jury of conspiring to violate the National Prohibition Act by possessing, manufacturing, selling, and transporting intoxicating liquor and related property in Massachusetts. After the verdict, they filed a motion in arrest of judgment claiming the indictment failed to allege an offense against the United States, which the district court denied before imposing sentence. The First Circuit affirmed, reasoning that the indictment adequately informed the defendants of the charges against them, that the detailed overt acts described the conspiracy, and that Rev. St. § 1025 cured any formal defects; it further upheld the Act's provisions as valid congressional enforcement of the Eighteenth Amendment. The court also addressed the use of prior convictions for impeachment but found no reversible error.

criminal lawfederal power

The case concerned two customers who filed reclamation petitions seeking to recover specific shares of stock from the trustees in bankruptcy of their stockbroker, arguing that the broker had bucketed their margin account transactions rather than executing actual purchases and sales, resulting in no genuine debit balances and wrongful repledging of the securities. The Circuit Court of Appeals reversed the district court's affirmance of the referee's denial of the petitions, ruling that the offered proof of bucketing was admissible and material because it would demonstrate the absence of lawful margin accounts and unauthorized repledging. The court held that the customers' fully identified securities were not subject to the cosurety contribution rules that apply to lawfully pledged collateral, so the stocks (or their equivalents) in the trustees' possession must be returned to the petitioners instead of going to the general bankruptcy estate.

business & regulatoryproperty