the government of New York State by Juanita Swedenburg and other owners of out-of-state wineries. In both cases, the state governments of Michigan and New York had argued that Section 2 of the Twenty-First Amendment granted them carte blanche to regulate liquor. One of their justifications for the laws was that by regulating out-of-state wineries that way, they might be able to hinder the shipment of alcohol to underage minors, which would serve a valid state purpose. The government of New York had won in the federal Second Circuit Court, and the government of Michigan had lost in the Sixth Circuit. The cases were consolidated and heard together by the US Supreme Court. In a 5–4 decision, the Supreme Court decided the states' laws were unconstitutional. The context of the Twenty-First Amendment was to return to the status quo that had existed before Prohibition. The Court made it clear that states have the power to regulate alcohol however they wished, including banning alcoholic beverages entirely within the state. Before Prohibition, the states did not have the power to violate the Dormant Commerce Clause, and the Twenty-First Amendment was not intended to grant them that power. Aftermath Michigan's liquor control board announced that it would recommend to the state government to ban all direct wine sales to consumers, which would join the 15 other states that currently ban all such sales. New York Governor George Pataki unveiled a bill that would limit each winery's direct sales to consumers to two cases per month per consumer. As a Wall Street Journal editorial noted, two cases per month is a relatively large amount of wine for a consumer, but the measure was intended to reduce competition for New York alcohol distributors. New York State enacted a bill in 2006 that allows direct shipment of wine to consumers on a reciprocal basis. New York residents can purchase wine that is shipped from a state that grants New York wineries the same rights. Since the ruling, many more states have allowed direct shipping from wineries. According to the Wine Institute, a public policy advocacy association of California wineries, 37 states permitted at least some form of direct shipping from wineries to consumers, as of July 2010. Different states have enacted different regulations. An editorial article on the commercial wine selling web site Appellation America states that many of the conditions in those regulations are so