South Dakota v. Dole
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| South Dakota v. Dole | |||||||||
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 Supreme Court of the United States |
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| Argued April 28, 1987 Decided June 23, 1987 |
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| Holding | |||||||||
| Congress may attach reasonable conditions to funds disbursed to the states. | |||||||||
| Court membership | |||||||||
| Chief Justice: William Rehnquist Associate Justices: William J. Brennan, Byron White, Thurgood Marshall, Harry Blackmun, Lewis Franklin Powell, Jr., John Paul Stevens, Sandra Day O'Connor, Antonin Scalia |
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| Case opinions | |||||||||
| Majority by: Rehnquist Joined by: White, Marshall, Blackmun, Powell, Stevens, Scalia Dissent by: Brennan Dissent by: O'Connor |
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South Dakota v. Dole, 483 U.S. 203 (1987), was a case in which the United States Supreme Court considered federalism and the power of the United States Congress under the Taxing and Spending Clause.
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[edit] Facts
In 1984, the United States Congress passed legislation withholding 5% of federal highway funds from states that did not adopt a minimum 21-year-old drinking age. South Dakota, a state that had allowed 19-year-olds to purchase beer containing up to 3.2% alcohol, sued to challenge the law, naming Secretary of Transportation Elizabeth Dole as the defendant because her office was responsible for enforcing the legislation.
[edit] Decision of the Court
The Supreme Court, in a 7-2 decision authored by Chief Justice William Rehnquist, ruled that Congress had engaged in a valid exercise of its power under the Taxing and Spending Clause, and did not violate the Twenty-first Amendment. Rehnquist said that Congress's conditional spending is subject to four restrictions:
- ( 1 ) The condition must promote "the general welfare;"
- ( 2 ) The condition must be unambiguous;
- ( 3 ) The condition should relate "to the federal interest in particular national projects or programs;" and
- ( 4 ) Other constitutional provisions may supersede conditional grants.
The first three restrictions, Rehnquist noted, are uncontested. This leaves the fourth restriction. The Tenth Amendment bars federal regulation of the States, and it has been suggested that the Twenty-First Amendment might prohibit federal regulation of the drinking age. Nevertheless, the Congressional condition of highway funds is merely a "pressure" on the State to comply, not a "compulsion" to do so, because the State's failure to meet the condition deprives it of only 5% of the highway funds it may obtain. Therefore, Congress has not run afoul of the Tenth or Twenty-First Amendments.
[edit] Dissent
Justices O'Connor and Brennan each filed dissents. O'Connor agreed that Congress may attach conditions on the receipt of federal funds, and that the Twenty-First Amendment gives states authority over laws relating to the consumption of alcohol. The attached condition on the states, O'Connor said, must be "reasonably related to the expenditure of funds." O'Connor disagreed with the Court's finding that withholding federal highway funds was reasonably related to deterring drunken driving in teenagers. She argued that the condition was both over and under-inclusive: it prevents teenagers from drinking when they are not going to drive, and it does not attempt to remedy the overall problem of drunken driving. Therefore, the relation here between the condition and spending is too attenuated:
| “ | [E]stablishment of a minimum drinking age of 21 is not sufficiently related to interstate highway construction to justify so conditioning funds appropriated for that purpose. | ” |
If the condition and spending are too attenuated, then they fail the court's "reasonable relation" test, falling outside the scope of Congress's power in the Constitution. Brennan, in a brief paragraph, states his agreement with O'Connor, stating that the Twenty-First Amendment "strikes the proper balance between federal and state authority".
