South Dakota v. Dole case brief

South Dakota v. Dole case brief summary

483 U.S. 203 (1987)

CASE SYNOPSIS

On certiorari from the United States Court of Appeals for the Eighth Circuit, petitioner State of South Dakota challenged a judgment ruling that 23 U.S.C.S. § 158, which reduced federal highway funding to states with a minimum drinking age below 21, did not violate U.S. Constitutional amendment XXI, or Congress's spending power, U.S. Constitutional Article I, § 8, cl. 1.

CASE FACTS

• Petitioner State permitted persons 19 years of age or older to purchase beer pursuant to S.D. Codified Laws § 35-6-27. 
• However, 23 U.S.C.S. § 158 permitted the reduction of federal highway funds otherwise allocable to a state if the state had a minimum drinking age below 21. 
• Petitioner sought a declaratory judgment that § 158 violated Congress's spending power,U.S. Constitutional Article I, § 8, cl. 1, and that it violated U.S. Constitutional amendment XXI. 
• The trial court rejected petitioner's claims, and the Court of Appeals for the Eighth Circuit affirmed. 

DISCUSSION

• On certiorari, the Court affirmed, holding that: 
• (1) the statute's indirect imposition of a minimum drinking age was a valid exercise of Congress's spending power, reasonably calculated to advance the general welfare and national concern of safe interstate travel; and 
• (2) the Twenty-First amendment was not violated as the statute did not induced petitioner to engage in unconstitutional activities.

CONCLUSION

The Court affirmed the appellate court's judgment.