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Supreme Court of the United States - 483 U.S. 203
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The case involves South Dakota's law allowing individuals aged 19 or older to purchase beer with up to 3.2% alcohol. South Dakota sued the Secretary of Transportation, claiming that a federal law that directs the Secretary to withhold a percentage of federal highway funds from states where the purchase or public possession of any alcoholic beverage by a person under 21 is legal violates constitutional limitations on congressional spending power and the Twenty-first Amendment. The Court of Appeals for the Eighth Circuit affirmed the District Court's rejection of South Dakota's claims. The Court found that Congress can indirectly encourage uniformity in the States' drinking ages through its spending power, even if it cannot regulate drinking ages directly. Congress has the power to attach conditions on the receipt of federal funds to further broad policy objectives, as part of its power to lay and collect taxes. This power is not limited by the direct grants of legislative power found in the Constitution. The spending power of Congress is subject to several general restrictions, including that it must be in pursuit of the general welfare, Congress must unambiguously condition the States' receipt of federal funds, conditions on federal grants may be illegitimate if they are unrelated to the federal interest in particular national projects or programs, and other constitutional provisions may provide an independent bar to the conditional grant of federal funds. Courts should defer substantially to the judgment of Congress when considering whether a particular expenditure is intended to serve general public purposes. The District Court's rejection of South Dakota's claims was affirmed.
Justice Brennan disagrees with the majority opinion and supports Justice O'Connor's view that the regulation of the minimum age for purchasing liquor is a state power under the Twenty-first Amendment. He asserts that Congress cannot impose conditions on federal grants that violate this right, as the Amendment already establishes the proper balance between federal and state authority.
The writer disagrees with the Court's decision to uphold the National Minimum Drinking Age Amendment as a valid exercise of the spending power. They argue that the amendment exceeds Congress' power to regulate commerce due to the Twenty-first Amendment. The writer also disagrees with the Court's application of the requirement that the condition imposed must be reasonably related to the purpose for which the funds are expended. They suggest that the Court should draw a clear line between permissible and impermissible conditions on federal grants based on the "germaneness" requirement.
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