Thursday, November 14, 2013

Reno v. Condon case brief

Reno v. Condon case brief summary
528 U.S. 141 (2000)

Petitioner sought review of the decision of the Court of Appeals for the Fourth Circuit, which affirmed the district court's decision granting summary judgment for respondents and permanently enjoining the enforcement of the Driver's Privacy Protection Act of 1994, 18 U.S.C.S. §§ 2721-2725 (1994 & Supp. III), against respondent, the State of South Carolina.

Respondents, state and its attorney general, sued defendant United States, alleging that the Driver's Privacy Protection Act of 1994 (DPPA), 18 U.S.C.S. §§ 2721-2725 (1994 & Supp. III), violated U.S. Constitutional amends. X and XI. The district court granted summary judgment for respondent and permanently enjoined the DPPA's enforcement against respondents. The appellate court affirmed.


  • On appeal, the court held the DPPA was a proper exercise of Congress' authority to regulate interstate commerce because drivers' information was an article of commerce and its sale or release into the interstate stream of business was sufficient to support congressional regulation. 
  • The court reject respondents' argument that the DPPA violated the principles of federalism contained in U.S. Constitutional Amendment X since it did not require the South Carolina Legislature to enact any laws or regulations, and it did not require state officials to assist in the enforcement of federal statutes regulating private individuals.

Judgment reversed because in enacting the Driver's Privacy Protection Act of 1994, Congress properly exercised its authority to regulate interstate commerce under the Commerce Clauseand did not violate the federalism principles contained in the Tenth Amendment.

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