South Dakota v. Hy Vee Food Stores, Inc.

During an undercover sting, a 19-year-old purchased whiskey from Hy Vee Food Stores (defendant) after two cashiers processed the sale without checking identification; Hy Vee was convicted as a corporate entity of the misdemeanor offense of selling alcohol to a minor and fined $200, though neither individual cashier was personally charged. Hy Vee appealed, arguing vicarious corporate criminal liability violated its substantive due process rights and that its internal policy against underage sales should shield it from liability.