Case Identification
Case name: South Dakota v. Dole
Court: Supreme Court of the United States
Year: 1987
Citation: 483 U.S. 203
Claim Presented
South Dakota challenged a federal statute that directed the Secretary of Transportation to withhold a percentage of federal highway funds from states in which the purchase or public possession of alcoholic beverages by persons under 21 years of age was lawful. The state contended that the statute exceeded Congress’s spending power and violated the Twenty-first Amendment.
Authority Cited
The Court examined Congress’s power under Article I, Section 8 of the Constitution to lay and collect taxes and to spend for the general welfare. The Court also addressed the Twenty-first Amendment, which grants states authority over alcoholic beverages within their borders.
Court’s Analysis
The Court evaluated whether Congress could condition the receipt of federal highway funds on state adoption of a minimum drinking age. The Court identified that the spending power is subject to several restrictions: the exercise must be in pursuit of the general welfare, conditions must be stated unambiguously, conditions must relate to the federal interest in particular national projects or programs, and conditions must not violate other constitutional provisions. The Court determined that encouraging a uniform minimum drinking age promoted the general welfare by addressing interstate concerns. The financial condition was found to bear a relationship to a federal interest in safe interstate travel. The Court stated that the condition was not a constitutional violation of the Twenty-first Amendment and that the financial inducement was pressure but not compulsion.
Disposition
The judgment of the Court of Appeals was affirmed. The statute was upheld.
Procedural Outcome
The federal statutory condition linking highway fund allocation to state minimum drinking age laws remained in effect.
Archival Note
This entry documents the judicial record in South Dakota v. Dole as preserved in the official reports. The decision addressed the scope of Congress’s spending power and clarified constitutional limits on conditioning federal funds in relation to state authority.