Douglas Furlong, Varietal Beer Company, and Vortex Brewing Co., LLC v. Anthony G. Brown, Attorney General of Maryland, and Jeffrey A. Kelly, Executive Director, Maryland Alcohol, Tobacco, and Cannabis Commission

Summary

The United States District Court for the District of Maryland granted Defendants’ motion under Federal Rule of Civil Procedure 59(e) to alter or amend the judgment in a challenge to Maryland’s Direct Delivery Law. The Court held that its injunction was overbroad because it swept beyond the residency and employee-delivery restrictions found unconstitutional and enjoined enforcement of other unchallenged licensing requirements. The Court ordered that the prior judgment be amended by separate amended judgment.

Holdings

1. Rule 59(e) relief was warranted because the injunction constituted clear error by extending beyond the constitutional violation established in the court's findings and conclusions.
2. The injunction was overbroad to the extent it enjoined enforcement of section 2-169(a)(2)(ii)–(iv) and other requirements

Questions Presented

1. Whether the post-trial injunction was overbroad because it barred enforcement of statutory provisions that were not challenged and were not found unconstitutional.
2. Whether the court should alter or amend the judgment under Federal Rule of Civil Procedure 59(e) to correct the overbroad injunction and prevent manifest injustice.