South Dakota v. Dole

South Dakota v. Dole, 483 U.S. 203 (1987), is a landmark decision of the United States Supreme Court.

Congress enacted the National Minimum Drinking Age Act, which directed the Secretary of Transportation to withhold 5% of federal highway funds from states whose minimum drinking age was below 21. South Dakota, which permitted alcohol sales to 19-year-olds, challenged the law as exceeding Congress’s spending power and violating the Twenty-First Amendment.

Significance

Chief Justice Rehnquist’s 7-2 opinion upheld the condition on federal highway funds. The Court applied a four-part test for conditional spending: (1) spending must be for the general welfare; (2) conditions must be unambiguous; (3) conditions must be related to the federal interest in the spending program; and (4) the condition must not violate other constitutional provisions. The condition here met all requirements because highway funds were related to the goal of safe interstate travel.

Category

US Federal Case Law