South Dakota v. Dole (1987) Case Brief PDF

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Case Name: South Dakota v. Dole (1987) – Federal Grant Conditions (pg.245-248) Rule of Law: Federal funds can be conditional under the spending power and contingent on the following:  General welfare  Conditions are unambiguous  Related to the federal interest and particular project or program  Conditions do not violate any other constitutional provision i.e. 10th amendment Facts:  South Dakota law permitted persons 19 years of age or older to purchase beer containing up to 3.2% alcohol  In 1984 Congressed enacted U.S.C. Sec. 158 which directed the Secretary of Transportation to withhold a percentage of federal high way funds otherwise allocable from State: o “in which the purchase of public possession . . . of any alcoholic beverage by a person who is less then twenty-one years of age is lawful.”  SD sued seeking declaratory judgement that Sec. 158 violates the constitutional limitations on congressional exercise of the spending power and violates the 25th amendment  Dist Crt ruled it constitutional and App Crt affirmed Issue: Whether Congress can withhold funds contingent on the states compliance with the federally imposed conditions. Holding: Chief Justice Rehnquist  The constitution empowers congress under the spending power… therefore Congress may attach conditions on the receipt of federal funds, and has repeatedly employed the power “to further broad policing objectives by conditioning receipt of federal moneys upon compliance by the recipient with federal statutory and administrative directives.”  Potential loss is not so great as to force states to comply with federal standards  Hospital v. Halderman (1981) – general restrictions o Limitations derived from the language of the constitution o Conditions must be unambiguous o Conditioner can’t be unrelated to federal interested the particular national project of program o Must not violate other constitutional provisions  Government can impose conditions as long as it is clearly expressed and states must know consequences of not participating – this case ruled in favor of the state  Conditions cannot be coercive (argument is more rhetoric (wordy, exaggeration) than fact)  No violation of the 10th amend because the potential loss is only 5% Dissent:  O’Connor o Sec 158 is a violation of the 25th amend Sec. 2 – setting the drinking age has nothing to do with highway safety construction

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Brennan o The power to regulate drinking minimum age falls within the powers reserved to the states under the 25th amend...