issouri, January 23, 1933; Ohio, January 23,
1933; Utah, January 23, 1933; Colorado, January 24, 1933; Massachusetts,
January 24, 1933; Wisconsin, January 24, 1933; Nevada, January 26, 1933;
Connecticut, January 27, 1933; New Hampshire, January 31, 1933; Vermont,
February 2, 1933; Maryland, March 24, 1933; Florida, April 26, 1933.

A proposed amendment which would authorize Congress to limit, regulate,
and prohibit the labor of persons under 18 years of age was passed by
Congress on June 2, 1924. This proposal at the time it was submitted to
the States was referred to as "the proposed 20th Amendment." It appears
officially in 43 Stat. 670.

The status of this proposed amendment is a matter of conflicting
opinion. The Kentucky Court of Appeals in Wise _v._ Chandler (270 Ky. 1
[1937]) has held that it is no longer open to ratification because: (1)
Rejected by more than one-fourth of the States; (2) a State may not
reject and then subsequently ratify, at least when more than one-fourth
of the States are on record as rejecting; and (3) more than a reasonable
time has elapsed since it was submitted to the States in 1924. The
Kansas Supreme Court in Coleman _v._ Miller (146 Kan. 390 [1937]) came
to the opposite conclusion.

On October 1, 1937, 27 States had ratified the proposed amendment. Of
these States 10 had previously rejected the amendment on one or more
occasions. At least 26 different States have at one time rejected the
amendment.

[m] The 21st Amendment was proposed by Congress on February 20, 1933,
when it passed the House [Cong. Rec. (72d Cong., 2d sess.) 4516], having
previously passed the Senate on February 16 [_Id._, 4231]. It appears
officially in 47 Stat. 1625. Ratification was completed on December 5,
1933, when the thirty-sixth State (Utah) approved the amendment, there
being then 48 States in the Union. On December 5, 1933, Acting Secretary
of State Phillips certified that it had been adopted by the requisite
number of States [48 Stat. 1749].

The several State conventions ratified the 21st Amendment on the
following dates: Michigan, April 10, 1933; Wisconsin, April 25, 1933;
Rhode Island, May 8, 1933; Wyoming, May 25, 1933; New Jersey, June 1,
1933; Delaware, June 24, 1933; Indiana, June 26, 1933; Massachusetts,
June 26, 1933; New York, June 27, 1933; Illinois, July 10, 1933; Iowa,
July 10, 1933; Connecticut, July 11, 1933; New Hampshire, July 11, 1933;
California, July 24, 1933; West Virginia, July