| South Dakota V. Dole |
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| 1987 in law | |
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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. DECISION OF THE COURT The Supreme Court, in a 7-2 decision authored by Chief Justice 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. 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 to attenuated. 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". EXTERNAL LINKS |
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