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South Dakota v. Dole

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Supreme Court of the United States
South Dakota v. Dole
Reference: 483 U.S. 203
Term: 1987
Important Dates
Argued: April 28, 1987
Decided: June 23, 1987
Outcome
United States Court of Appeals for the Eighth Circuit affirmed
Majority
Chief Justice William Rehnquist • Byron White • Thurgood Marshall • Harry Blackmun • Lewis Powell • John Stevens • Antonin Scalia
Dissenting
Sandra Day O'Connor • William J. Brennan

South Dakota v. Dole is a case decided on June 23, 1987, by the United States Supreme Court, which ruled that Congress could condition state grants on certain policy requirements without exceeding its spending power and violating the Tenth Amendment.[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. The Supreme Court affirmed the ruling of the United States Court of Appeals for the Eighth Circuit, holding that the National Minimum Drinking Age Act's reduction of funding for certain states did not exceed Congress' spending power under the General Welfare Clause, encroach on the reserved powers of states under the Tenth Amendment, or violate the Twenty-first Amendment.[1][2]

HIGHLIGHTS
  • The case: Congress enacted the National Minimum Drinking Age Act in 1984, which contained a provision withholding a percentage of federal highway funds from states with drinking ages under 21. South Dakota, which had a minimum drinking age of 19, filed suit to acquire the withheld percentage.
  • The issue: Did Congress' conditioning of federal highway funds on state drinking age laws exceed its spending powers or violate the Twenty-first Amendment?
  • The outcome: The Supreme Court held that Congress could condition grants on certain state policy requirements without exceeding its spending power. The court ruled that since the law indirectly encouraged states to enact higher drinking ages, it did not violate the Twenty-first Amendment.


    • 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. Chief Justice William Rehnquist argued the conditioning of grant money was not coercive and that since Congress acted indirectly to encourage uniformity in state drinking ages, the law was constitutional, "even if Congress may not regulate drinking ages directly" (a question the opinion did not address).

    Background

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    Congress enacted the National Minimum Drinking Age Act in 1984, which contained a provision ordering the U.S. Secretary of Transportation to withhold 5% of a state's federal highway funds during the first year the law became effective and 10% for following years if a state's minimum drinking age was under 21.[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. After the United States Court of Appeals for the Eighth Circuit ruled that the law was constitutional and the federal government could withhold the funds from South Dakota, the state appealed to the Supreme Court.[1][2]

    Oral argument

    Oral argument was held on April 28, 1987. The case was decided on June 23, 1987.[1][2]

    Decision

    The Supreme Court decided 9-0 that the First Amendment, as incorporated to the states under the Due Process Clause, prohibited the state from distinguishing religious solicitation from other types of solicitation for the purpose of licensing and from prosecuting peaceful religious advocates for incitement.[1][2]

    Opinions

    Opinion of the court

    Chief Justice William Rehnquist, writing for the court, argued that Congress could condition grant money to states under the Spending Clause of Article 1, Section 8, of the Constitution to encourage states to implement policies in the national interest. 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.

    “ Here, Congress has acted indirectly under its spending power to encourage uniformity in the States' drinking ages. Thus, objectives not thought to be within Article I's "enumerated legislative fields," id. at 297 U. S. 65, may nevertheless be attained through the use of the spending power and the conditional grant of federal 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 means it chose to address this dangerous situation were reasonably calculated to advance the general welfare. The conditions upon which States receive the funds, moreover, could not be more clearly stated by Congress.
    ...
    These cases establish that the "independent constitutional bar" limitation on the spending power is not, as petitioner suggests, a prohibition on the indirect achievement of objectives which Congress is not empowered to achieve directly. Instead, we think that the language in our earlier opinions stands for the unexceptionable proposition that the power may not be used to induce the States to engage in activities that would themselves be unconstitutional. Thus, for example, a grant of federal funds conditioned on invidiously discriminatory state action or the infliction of cruel and unusual punishment would be an illegitimate exercise of the Congress' broad spending power. But no such claim can be or is made here. Were South Dakota to succumb to the blandishments offered by Congress and raise its drinking age to 21, the State's action in so doing would not violate the constitutional rights of anyone.[2][3]

    		”

    Dissent

    Justices Sandra Day O'Connor and William J. Brennan dissented. 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. 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.

    “ This case, however, falls into neither class. As discussed above, a condition that a State will raise its drinking age to 21 cannot fairly be said to be reasonably related to the expenditure of funds for highway construction. The only possible connection, highway safety, has nothing to do with how the funds Congress has appropriated are expended. Rather than a condition determining how federal highway money shall be expended, it is a regulation determining who shall be able to drink liquor. As such, it is not justified by the spending power.

    ...
    Of the other possible sources of congressional authority for regulating the sale of liquor, only the commerce power comes to mind. But in my view, the regulation of the age of the purchasers of liquor, just as the regulation of the price at which liquor may be sold, falls squarely within the scope of those powers reserved to the States by the Twenty-first Amendment.[2][3]

    		”


    Justice Brennan dissented separately, claiming states had the right to regulate the minimum drinking age under the Twenty-first Amendment. He argued that since the right was reserved to the states, Congress' conditioning of funds abridged their constitutional right.

    “ I agree with JUSTICE O'CONNOR that regulation of the minimum age of purchasers of liquor falls squarely within the ambit of those powers reserved to the States by the Twenty-first Amendment. See post at 483 U. S. 218. Since States possess this constitutional power, Congress cannot condition a federal grant in a manner that abridges this right. The Amendment, itself, strikes the proper balance between federal and state authority. I therefore dissent.[2][3] ”

    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 v. Dole has been cited in other cases such as National Federation of Independent Business v. Sebelius (2012) to rule other federal grant conditions as unconstitutional, even though the grant conditions in the National Minimum Drinking Age Act were found to be constitutional.[2]

    The majority in South Dakota v. Dole held that the federal government could condition federal funding on state policies if:[2]

    1. The congressional spending was for the general welfare.
    2. The conditions for the grant were unambiguous.
    3. The conditions for the grant were related to a valid national interest.
    4. Congress did not use the spending power to induce states to enact unconstitutional policies.
    5. The conditions did not cross the line from encouragement to coersion (in South Dakota v. Day, the court argued the condition was not coersive because the percentage of withheld funds were nominal enough that a state could resist Congress' pressure).

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Oyez, "South Dakota v. Dole," accessed June 15, 2022
    2. ↑ 2.00 2.01 2.02 2.03 2.04 2.05 2.06 2.07 2.08 2.09 2.10 Justia, "South Dakota v. Dole, 483 U.S. 203 (1987)," accessed June 15, 2022
    3. ↑ 3.0 3.1 3.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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