Hawke v. Smith

Meanwhile, a petition was signed by at least six percent of the voters and, in the ensuing referendum, a majority of Ohio voters voted against prohibition, seemingly invalidating the passage of the 18th Amendment.

The issue before the court was whether or not a state had a right to reserve to its people the right to review its legislature's ratification of federal amendments.

Thus in the case of Ohio, the idea of "state legislature" came with the limit of not being able to ratify a federal amendment without review by the people of the state, and, thus, the amendment had not been ratified.

On June 1, 1920, the Court ruled that Ohio voters could not overturn the state legislature's approval of the Eighteenth Amendment.

Second, the fact that the amendment passed in Ohio despite a majority of voters voting against it fostered the idea that Prohibition was the work of powerful groups and not the people themselves.