South Dakota V. Dole (1987) Case Brief

Case brief
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Case: United States v. Morrison
Cite: 483 U.S. 203 (1987)
Vote: 7-2
Opinion: Rehnquist
Facts of the case:
The congress during 1984 enacted legislation commanding the secretary of transportation (Elizabeth Dole) to hold back 5% of federal highly funding from states which did not comply with a 21-year-old minimum drinking age Act.
The state of South Dakota challenged the ruling because it allowed persons of 19 years of age to buy alcohol with contents up to 3.2%.
The congress enacted legislation known as the National Minimum Drinking Age Act.
Legal question:
Did congress breach the twenty-first amendment, or exceed its spending powers, by enacting a legislation encouraging the reward of federal highway funds on the states’ compliance to uniform minimum drinking age?
Statutory provision:
The National Minimum Drinking Age Act
Constitutional provision:
Tenth amendment
Twenty-first amendment
Reasoning:
In the U.S Supreme Court, seven judges supported the legislation while two judges disapproved the law.
The Supreme Court ruled the congress acted implicitly to promote uniformity in states’ drinking ages, and, therefore. The act was within constitutional limits.
The Supreme Court ruled the law corresponded with interest of the general welfare of people, and, therefore, the decision adopted was reasonable.
The court ruled that the limitations of the twenty-first amendment on spending power were not interdictions on congressional efforts to attain federal objectives indirectly.
5% loss of highway funds was not excessively coercive.
The Supreme Court maintained that the legislation represented a valid utilization of congressional power under the spending clause. Therefore, the legislation did not breach the rights of the states.
The Supreme Court developed a five-point rule for reflecting on the constitutionality of expenditure minimization in this nature. First-point is that the...