south dakota v dole outcome

Justia Law, 2015. 2023 National Constitution Center. 158 (1982 ed., Supp. I, Sec. Congress did not create a condition that "might be so coercive as to pass the point at which "pressure turns into compulsion. When South Dakota challenged this law, ultimately sending the case up to the Supreme Court, the Court assessed the case and the constitutionality based off of four aspects- (1) If the spending power was in pursuit of the general welfare (2) the conditions for the grant were clearly stated (3)the conditions for receiving the grant were related to a federal interest in the national project and finally (4) if the case had used their spending power to induce states to do things that would themselves be unconstitutional. . The state appealed to the Supreme Court and the Court granted certiorari. Feb. 1998. On certiorari, the Courtheld that: (1) the statute's indirect imposition of a minimum drinking age was a valid exercise of Congress's spending power, reasonably calculated to advance the general welfare and national concern of safe interstate travel; and (2) theTwenty-First amendmentwas not violated as the statute did not induce petitioner to engage in unconstitutional activities. Here, Congress has acted indirectly under its spending power to encourage uniformity in the States' drinking ages. . In the majority opinion, Rehnquist found that the Spending Clause justified Congress in imposing this law, despite Tenth Amendment protections for states. 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. This Comment argues for more . Withhold 5% of education funding from states unless their schools can demonstrate certain achievement levels on standardized tests? The act determined that a percentage of federal funding for state highways could be withheld if states failed to raise their minimum drinking age to 21. 158permitted the reduction of federal highway funds otherwise allocable to a state if the state had a minimum drinking age below 21. Tellinghuisen is a member of the United States Supreme Court Bar (where he argued South Dakota v. Elizabeth Dole, 107 S. Ct. 2793 (1987), the United States Court of Appeals, Eighth Circuit, United States District Court and South Dakota Bar Association. https://www.thoughtco.com/south-dakota-v-dole-4175647 (accessed June 28, 2023). Congressional spending power is limited by three general restrictions: According to the majority, Congress' aim to prevent teenage drunk driving demonstrated an interest in general welfare. ThoughtCo, Aug. 25, 2020, thoughtco.com/south-dakota-v-dole-4175647. Join the BRI Network! South Dakota v. Dole, 483 U.S. 203 (1987), was a case in which the United States Supreme Court considered the limitations that the Constitution places on the authority of the United States Congress when Congress uses its authority to influence the individual states in areas of authority normally reserved to the states. Register here Justice OConnor argues that the conditioning of federal highway funds should be related to the purpose for which the funds are disbursed. South Dakota v. Dole | Case Brief for Law Students | Casebriefs The justices then turned to the more contentious issue: whether the act violated the state's 21st Amendment right to regulate the sale of alcohol. Casebriefs is concerned with your security, please complete the following, The Structure Of The Constitution's Protection Of Civil Rights And Civil Liberties, Fundamental Fights Under Due Process And Equal Protection, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam). I, 8, cl. Start your constitutional learning journey. But no such claim can be or is made here. . Quimbee has over 16,300 case briefs (and counting) keyed to 223 casebooks https://www.quimbee.com/case-briefs-. In NFIB v. Sebelius (2012) Chief Justice Roberts cited South Dakota v. Dole saying that the conditions for which the funds would be held from the States who failed to adopt a minimum drinking age were relatively mild encouragementand that in doing so, or refusing not to do was South Dakotas prerogative. . May Congress withhold funds from states that do not maintain a 21 year old drinking age? Yet, the states with lower drinking ages would cross state lines to drink alcohol legally. Hollister v. Benedict & Burnham Manufacturing Co. General Talking Pictures Corp. v. Western Electric Co. City of Elizabeth v. American Nicholson Pavement Co. Consolidated Safety-Valve Co. v. Crosby Steam Gauge & Valve Co. United Dictionary Co. v. G. & C. Merriam Co. White-Smith Music Publishing Co. v. Apollo Co. Straus v. American Publishers Association, Interstate Circuit, Inc. v. United States, Fashion Originators' Guild of America v. FTC. As a consequence, the Department of Transportation will withhold approximately 5% of the federal highway funds earmarked for the state. This page was last edited on 29 November 2022, at 18:40. Incident to this power, Congress may attach conditions on the receipt of federal funds, and has repeatedly employed the power to further broad policy objectives by conditioning receipt of federal moneys upon compliance by the recipient with federal statutory and administrative directives. . Society for Relief of Distressed Pilots, Allegheny v. ACLU (Greater Pittsburgh Chapter), American Legion v. American Humanist Association, Arizona Free Enterprise Clubs Freedom PAC v. Bennett, Baldwin v. Fish & Game Commission of Montana, Brown v. Entertainment Merchants Association, Christian Legal Society Chapter of the University of California, Hastings College of the Law v. Martinez, District Attorneys Office for the Third Judicial District v. Osborne, Flamm v. American Association of University Women. "South Dakota v. Dole: The Case and Its Impact." South Dakota v. Dole established a five-point test for determining whether Congress' methods for promoting state policies were constitutional under the Spending Clause. South Dakota's minimum drinking age was nineteen years old, and Congress passed a law establishing a national minimum drinking age of twenty-one years old. SOUTH DAKOTA v. DOLE Syllabus SOUTH DAKOTA v. DOLE, SECRETARY OF TRANSPORTATION CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT No. Moreover, the relatively small financial inducement offered by Congress here -- resulting from the State's loss of only 5% of federal funds otherwise obtainable under certain highway grant programs -- is not so coercive as to pass the point at which pressure turns into compulsion. South Dakota v. Dole | Case Brief for Law Students | Casebriefs It would not markedly increase safety because teenagers pose only a small part of the drunken driving problem in this Nation. She concluded that establishing a national minimum drinking age had nothing to do with highway funding. She argued that the condition was both overinclusive and underinclusive: it prevented teenagers from drinking when they are not going to drive on federal and federally funded highways, and it did not attempt to remedy the overall problem of drunken driving on federal and federally funded highways. L. A. Westermann Co. v. Dispatch Printing Co. Miller Music Corp. v. Charles N. Daniels, Inc. Pub. South Dakota, which permits persons 19 years old or older to purchase beer containing up to 3.2% alcohol, sued in Federal District Court for a declaratory judgment that 158 violates the constitutional limitations on congressional exercise of the spending power under Art. Here, if South Dakota were to succumb to Congress' blandishments and raise its drinking age to 21, its action would not violate anyone's constitutional rights. [1][2], The case concerned the National Minimum Drinking Age Act, which ordered the Secretary of Transportation to withhold a percentage of federal highway funding from states that set the minimum drinking age below 21. If the spending power is to be limited only by Congress notion of the general welfare, the reality, given the vast financial resources of the Federal Government, is that the Spending Clause gives power to the Congress to tear down the barriers, to invade the states jurisdiction, and to become a parliament of the whole people, subject to no restrictions save such as are self-imposed. This, of course, . . Affairs Associates, Inc. v. Rickover. Conditioning the receipt of federal funds was not unconstitutional as long as it was in pursuit of the general welfare, as long as it was clear to the states that they had a choice and were aware of the consequence for noncompliance, and finally, as long as the conditions for highway funding were related to a national concern, which in this case was highway safety. BRIs Comprehensive US History digital textbook, BRIs primary-source civics and government resource, BRIs character education narrative-based resource. SOUTH DAKOTA v. DOLE, 483 U.S. 203 (1987) | FindLaw U.S. Const. The Understanding Law Video Lecture Series: Monthly Subscription ($19 / Month) This case illustrates that the Spending Clause is one of the most broadly interpreted provisions on the powers of the federal government, which makes it a useful basis for regulation. [O]bjectives not thought to be within Article Is enumerated legislative fieldsmay nevertheless be attained through the use of the spending power and the conditional grant of federal funds. Using powers derived from the 21st Amendment, 29 states changed the minimum age to either 18, 19, or 20. Drunk-driving accidents had dropped by 50 percent since the law was passed. In 1987 the Supreme Court held in South Dakota v. Dole (a 7-2 decision written by Chief Justice Rehnquist, in which Justice Scalia joined) that Congress could insist that South Dakota increase the minimum drinking age to 21 as a condition of obtaining federal highway funds. Art. v. Varsity Brands, Inc. A South Dakota state statute permitted the sale of beer containing up to 3.2 percent of alcohol to those 19 and older. III), which directs the Secretary of Transportation to withhold a percentage of federal highway funds otherwise allocable from States . (a) Incident to the spending power, Congress may attach conditions on the receipt of federal funds. Also this resource shows statistics from all the states. . The significance of the case is that the USSC said that Congress was doing this for the general welfare,being able to promote the general welfare through the spending powers, and that it did not violate the twenty-first amendments spending power. Drunk driving accidents became a heightened concern for Congress which in turn passed the National Minimum Drinking Age Act as a way to encourage a uniform standard across state lines. Another factor is that, despite the small price of resistance, most states complied with little grumbling. South Dakota brought a suit against the federal government in 1986 alleging that Congress had stepped beyond its Art. But in South Dakota v Dole, Court explicitly deemed the act of conditioning receipt for federal highway funds constitutional. The "coerciveness" of the Act varied from state to state, though the Supreme Court never took that into account. South Dakota v. Dole became a precedent case and mentioned multiple times in the 1990s as the major guideline for which other cases argued over Congress spending power. Congress' encouragement to the States to impose a minimum drinking age of 21 years is a constitutional use of the taxing and spending power. The breadth of this power was made clear in United States v. From this they wanted every state to change their drinking age twenty-one, or they could lose a percentage of their federal highway funds. . As a result the PCDD (Presidents Commission Against Drunk Driving) was established to make recommendations to lower the number of alcohol related deaths. The conditions upon which States receive the funds, moreover, could not be more clearly stated by Congress. United States v. Paramount Pictures, Inc. Fred Fisher Music Co. v. M. Witmark & Sons. 158, which directs the Secretary of Transportation to withhold a percentage of federal highway funds otherwise allocable from Statesin which the purchase or public possession . South Dakota v. Dole | Constitution Center Why it matters: The Supreme Court determined that Congress could attach conditions to state grants without exceeding its constitutional authority to tax and spend or violating state rights. Dole: South Dakota v. Dole was a landmark Supreme Court case that revolved around federalism and the power of the United States Congress under the Taxing and Spending Clause. Congress was able to effectively establish a national minimum drinking age, even though this is not a power delegated to it in Article I. The concern for the drinking age was legally in full effect for all states. . . Pp. The 10th Amendment: Text, Origins, and Meaning, Timeline of Gun Control in the United States, What Is Administrative Law? OMalley, Patrick, and Alexander Wagenaar. . By the time South Dakota v. Dole was decided, the case was moot. In 1984, Congress passed 23 U.S.C. But[it]is not a condition on spending reasonably related to the expenditure of federal funds and cannot be justified on that ground. The states had a choice whether to accept or reject the federal funds, which would be on a conditional basis, therefore retaining their authority. Star Athletica, L.L.C. The legislation was in the pursuit of the general welfare. In this case, the funds being allocated to the states are for the promotion and construction of highway safety., and not to regulate the drinking age. . Schechter Poultry Corporation v. United States, Houston, East & West Railway Company v. United States, National Labor Relations Board v. Jones & Laughlin Steel Corp, Heart of Atlanta Motel, Inc. v. United States, Katzenbach v. McClung, Sr. and McClung, Jr, Garcia v. San Antonio Metropolitan Transit Authority, Aaron B. Cooley v. The Board of Wardens of the Port of Philadelphia ex rel. O'Connor argued that the minimum drinking age condition for states to receive federal highway funds was not sufficiently related to Congress' interests in expending the funds and consequently exceeded Article 1, Section 8, spending power. We have repeatedly said that Congress may condition grants under the spending power only in ways reasonably related to the purpose of the federal program. The four friends, all nineteen years of age, left their home state and crossed into South Dakota, because in South Dakota they could legally buy beer. In a 7-to-2 decision, the Court held that Congress did not exceed its spending powers, or violate the Twenty-First Amendment, by passing legislation conditioning the award of the federal highway funds on the states adoption of a uniform minimum drinking age. Can Congress withhold funds from states that don'trequire a minimum drinking age of 21 years old? This goal of the interstate highway system had been frustrated by varying drinking ages among the States. Use this button to switch between dark and light mode. California Retail Liquor Dealers Association v. Midcal Aluminum Inc.(1980), Your email address will not be published. She claimed that since the law's conditioning of funds was unconstitutional under Congress' spending power, the Twenty-first Amendment reserved authority over the drinking age to the states, and the highway funds could not be withheld from South Dakota. Yes. Under the Constitution Congress is granted specific power to tax and spend for the general welfare of the country. Thus, objectives not thought to be within Article I's enumerated legislative fields may nevertheless be attained through the use of the spending power and the conditional grant of federal funds. This case, however, falls into neither class. 1, of the Constitution and violates the Twenty-first Amendment. Pp. [1][2], South Dakota, which had a minimum drinking age of 19, challenged the law, claiming it exceeded Congress' spending power and violated the Twenty-first Amendment. (HTML text, see Section 158), Arizona State Legislature v. Arizona Independent Redistricting Commission, Immigration and Naturalization Service v. Chadha, Wabash, St. Louis & Pacific Railway Co. v. Illinois, Hunt v. Washington State Apple Advertising Commission, White v. Mass. XXI. In South Dakota v. Dole (1987), the Supreme Court upheld a federal law denying 5% of federal highway funds to states that refused to enact a law raising their drinking age to 21 (a measure the federal government claimed was related to promoting highway safety). The greatest proportion of this decline was among adolescents aged 16 to 20 year olds, indicative of the need for the Minimum Drinking Age Act. 2d 171, 1987 U.S. . Justices Sandra Day O'Connor and William J. Brennan dissented. Spitzer, Elianna. S.D. Title 23 U.S.C. Can Congress Forbid A State from Cutting its Taxes? Article I, section 8 of the Constitution says The Congress shall have power toprovide for the general welfare of the United States How did the Court apply this clause to. Your email address will not be published. I, 8, cl. Definition and Examples, What Is the Commerce Clause? . . Not only did the case prove significance legally, but it also had a substantial impact on the country as a whole. Since States possess this constitutional power, Congress cannot condition a federal grant in a manner that abridges this right. South Dakota v. Dole - Ballotpedia This article is meant to serve as a guide to show the effects per state of the minimum drinking age. But it is not entitled to insist as a condition of the use of highway funds that the State impose or change regulations in other areas of the States social and economic life because of an attenuated or tangential relationship to highway use or safety., Visiting Professor, Georgetown University Law Center and Senior Fellow at the Brennan Center for Justice, Associate Professor, Sandra Day O'Connor College of Law at Arizona State University. External Relations: Moira Delaney Hannah Nelson Caroline Presnell South Dakota v Dole (1987) is a case that came about after a teenager was killed by a drunk driver. All Rights Reserved. [1][2], Oral argument was held on April 28, 1987. She viewed the relation between the condition and spending as being too attenuated: "establishment of a minimum drinking age of 21 is not sufficiently related to interstate highway construction to justify so conditioning funds appropriated for that purpose.". South Dakota sues to force the federal government to pay the full amount of federal highway funds. Congress found that the differing drinking ages in the States created particular incentives for young persons to combine their desire to drink with their ability to drive, and that this interstate problem required a national solution. The landmark case we explore this month isSouth Dakota v. Dole(1987), which illustrates a conflict between state and federal power over the establishment of a minimum drinking age. According to Cohen, the Act did not violate the 21st Amendment or go beyond the Congressional Spending Powers laid out in Article I of the Constitution. at 297 U. S. 65, may nevertheless be attained through the use of the spending power and the conditional grant of federal funds. [W]e find this legislative effort within constitutional bounds even if Congress may not regulate drinking ages directly. Looking at findings that the different state drinking ages created an incentive to drink and drive, the Court found the law consistent with the goal of promoting the general welfare of the nation. Codified Laws 35-6-27 (1986). While she did not disagree with the majority's overall test, O'Connor was not persuaded that a condition related to highway funds was reasonably related to the goal of reducing drunk driving by young people. Similarly, in the case of United States v. Lopez, the Court declared it unconstitutional for Congress to condition receipt of federal prison funds. art. South Dakota v. Dole | Case Brief for Law School | LexisNexis South Dakota, which permits persons 19 years old or older to purchase beer containing up to 3.2% alcohol, sued in Federal District Court for a declaratory judgment that 158 violates the constitutional limitations on congressional exercise of the spending power under Art. Congress passed a law that withheld a certain percentage of federal funds to any state with a drinking age lower than 21. Before the prohibition of alcohol, the drinking age varied from state-to-state with the most states not enforcing a drinking age at all. Held. . South Dakota v Dole Flashcards | Quizlet 1, of the Constitution, and violates the Twenty-first Amendment. of any alcoholic beverage by a person who is less than twenty-one years of age is lawful. . As we explain below, we find this legislative effort within constitutional bounds even if Congress may not regulate drinking ages directly. In other words, while Congress cannot force states to do its bidding . Co. Patent and Trademark Office v. Booking.com B. V. Immigration and Naturalization Service v. St. Cyr, Department of Homeland Security v. Thuraissigiam. 17-494. Required fields are marked *. South Dakota v. Dole | The Federalist Society Justice Brennan dissented separately, claiming states had the right to regulate the minimum drinking age under the Twenty-first Amendment. We contribute to teachers and students by providing valuable resources, tools, and experiences that promote civic engagement through a historical framework. South Dakota v. Dole | Case Brief for Law Students | Casebriefs Rather than determining how federal highway money shall be [spent], it is a regulation determining who shall be able to drink liquor.. Following, the 21st amendment was ratified in December 1933, repealing the prohibition. The most effective way to secure a freer America with more opportunity for all is through engaging, educating, and empowering our youth. Points of Law - Legal Principles in this Case for Law Students. . Calling the law merely relatively mild encouragement to the States to enact higher minimum drinking ages, the Court found the federal law constitutional. Incident to this power, Congress may attach conditions on the receipt of federal funds . Energy Reserves Group v. Kansas P. & L. Co. Keystone Bituminous Coal Ass'n v. DeBenedictis, Northeast Bancorp v. Federal Reserve Board of Governors, https://en.wikipedia.org/w/index.php?title=South_Dakota_v._Dole&oldid=1124634215, United States Constitution Article One case law, United States Supreme Court cases of the Rehnquist Court, United States Twenty-first Amendment case law, Short description is different from Wikidata, Creative Commons Attribution-ShareAlike License 4.0. In my view, establishment of a minimum drinking age of 21 is not sufficiently related to interstate highway construction to justify so conditioning funds appropriated for that purpose. III) directs the Secretary of Trans- portation to withhold a percentage of otherwise allocable . BRENNAN, J., post p. 483 U. S. 212, and O'CONNOR, J., post p. 483 U. S. 212, filed dissenting opinions. This consisted of evaluating whether the spending promotes the general welfare, the condition is unambiguous, the condition has a connection to a federal interest in certain national projects or programs, the condition is not unconstitutional in itself, and the condition is not overly coercive. The Court ruled that Spending Clause measures must meet four requirements in order . The Court today upholds the National Minimum Drinking Age Amendment as a valid exercise of the spending power conferred by Article I, 8. The dissent focused on whether conditioning federal highway funds was directly connected to the sale of alcohol. In 1988, Wyoming was the last state to raise its minimum drinking age to 21. . Justices William Brennan and Sandra Day OConnor both dissent on the unrelated ground of the Twenty-first Amendment, which relegates regulation of alcohol sales to the states. Issue. When Congress appropriates money to build a highway, it is entitled to insist that the highway be a safe one. Research: Josh Altic Vojsava Ramaj Because Congress could constitutionally condition grant money to indirectly influence state policy (regardless of whether Congress could constitutionally implement the desired policy itself), Rehnquist argued the law was constitutional under the Twenty-first Amendment because it did not exert so much pressure as to be coercive and it did not pressure South Dakota into violating its constitution. Congress thus applied pressure, but not irresistible pressure. 483 U. S. 206-212. 1. The means it chose to address this dangerous situation were reasonably calculated to advance the general welfare. 1, of the Constitution and violates the Twenty-first Amendment. F. W. Woolworth Co. v. Contemporary Arts, Inc. Motion Picture Patents Co. v. Universal Film Manufacturing Co. Inwood Laboratories, Inc. v. Ives Laboratories, Inc. San Francisco Arts & Athletics, Inc. v. United States Olympic Committee, College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board. The Amendment, itself, strikes the proper balance between federal and state authority. O'Connor also reasoned that the condition was both over-inclusive and under-inclusive. Congress required states to set the minimum drinking age at 21, or lose 10% of federal funding for their highways. ". Note from the Editor: Civil Rights Practice Group, Nicholas Quinn Rosenkranz, Ted Cruz, David L. Sloss, Edwin D. Williamson. She says that the 21st amendment gives this power solely to the states. On April 28, 1987 South Dakota sued in United States District Court seeking a declaratory judgment that stating that the Minimum Drinking Age Act violated the constitutional limitations on congressional exercise of the spending power and violates the Twenty-first Amendment to the United States Constitution. Retrieved from https://www.thoughtco.com/south-dakota-v-dole-4175647. 483 U. S. 209-212. Thus, objectives not thought to be within Article I's "enumerated legislative fields," id. South Dakota v. Dole, 483 U.S. 203 | Casetext Search + Citator Make your investment into the leaders of tomorrow through the Bill of Rights Institute today! . . In 1791, the 10th amendment was ratified, basically stating that any powers that were not explicitly delegated by the Constitution or prohibited by it to the States are then reserved individually to the States or to the people. With strong support from Mothers against Drunk Driving, the National Parent Teacher Association and other groups, Congress in 1984 passed the Minimum Drinking Age Act which gave states a financial incentive to adopt a higher drinking age. Cooper Industries, Inc. v. Leatherman Tool Group, Inc. TrafFix Devices, Inc. v. Marketing Displays, Inc. Dastar Corp. v. Twentieth Century Fox Film Corp. Lexmark International, Inc. v. Static Control Components, Inc. Zacchini v. Scripps-Howard Broadcasting Co. Sony Corp. of America v. Universal City Studios, Inc. Community for Creative Non-Violence v. Reid. The state of South Dakota had a long-standing law that set the drinking age at 19 for consumption of beer that contained up to 3.2% alcohol. The question that arose from this act was, Did Congress exceed its spending power, or violate the 21st Amendment, by passing legislation conditioning the award of federal highway funds states adoption of a uniform minimum drinking age? In a 7 to 2 decision the USSC held that Congress acted indirectly to encourage uniformity in the states drinking ages, was within the constitutional bounds.

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