The U.S. Court of Appeals for the First Circuit considered a challenge to Rhode Island's liquor laws that argued consumers have been wrongly denied access to alcohol deliveries from out-of-state retailers in violation of the Commerce Clause.

The court vacated the district court's granting of summary judgment to the defendants as to the constitutionality of the in-state-presence requirement for retailers, remanding the issue for a fuller consideration of the parties' respective offers of proof. It also vacated the lower court's ruling that the plaintiffs' challenge to the common-carrier restriction was nondiscriminatory as the relevant statutory and regulatory provisions made no distinction between in-state and out-of-state retailers.