South Dakota v. Dole
"South Dakota v. Dole" is a significant Supreme Court case that addressed the intersection of state governance and federal legislative power concerning the minimum drinking age. In this case, South Dakota challenged a federal law requiring states to enforce a minimum drinking age of twenty-one to qualify for federal highway funds. The state argued that the authority to regulate alcohol was a power reserved to the states following the repeal of Prohibition and contended that the federal mandate violated the Constitution's taxing and spending clause.
The Supreme Court ruled in a 7-2 decision that the federal government could impose conditions on states receiving federal funds, provided that four criteria were met: the spending must serve the general welfare, the conditions must be clear, the conditions must relate to a federal interest in the project, and they must not violate other constitutional provisions. Notably, dissenting justices argued that the federal interest in highway construction did not sufficiently justify interference in state control over a matter like the drinking age. This ruling highlighted the ongoing debate over the balance of power between state and federal authorities and set a precedent for how conditional funding can be utilized to influence state law.
South Dakota v. Dole
Date: June 23, 1987
Citation: 483 U.S. 203
Issue: Federal supremacy
Significance: The Supreme Court upheld congressional legislation mandating that states impose a minimum drinking age of twenty-one as a condition for receiving their full complement of federal highway funds.
By a 7-2 vote, the Supreme Court upheld congressional legislation mandating that states impose a minimum drinking age of twenty-one as a condition for receiving their full complement of federal highway funds. South Dakota had long had a minimum drinking age lower than twenty-one and argued that states had the right to govern rules over alcoholic beverages after the repeal of Prohibition. South Dakota further argued that the federal law violated federal power under the taxing and spending clause in the Constitution. The Court ruled against the state, holding that four conditions must be met for congressional restrictions on grants to states. First, the spending must be within the general welfare; second, the restriction must be unambiguous; third, the restriction must be related to a federal interest in the project; and fourth, other constitutional provisions may not be violated. Justice William J. Brennan, Jr., dissented as did Justice Sandra Day O’Connor, who found that the third item the federal government’s interest in highway construction was insufficiently related to the minimum drinking age to merit federal interference in a traditionally state activity.
