SOUTH DAKOTA v. DOLE

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Case Basics
Docket No. 
86-260
Petitioner 
South Dakota
Respondent 
Dole
Advocates
(Argued the cause for the respondent)
(Argued the cause for the petitioner)
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Facts of the Case 

In 1984, Congress enacted legislation ordering the Secretary of Transportation to withhold five percent of federal highway funds from states that did not adopt a 21-year-old minimum drinking age. South Dakota, a state that permitted persons 19 years of age to purchase alcohol, challenged the law.

Question 

Did Congress exceed its spending powers, or violate the Twenty-first Amendment, by passing legislation conditioning the award of federal highway funds on the states' adoption of a uniform minimum drinking age?

Conclusion 
Decision: 7 votes for Dole, 2 vote(s) against
Legal provision: 23 U.S.C. 158

No. In a 7-to-2 decision, the Court held that Congress, acting indirectly to encourage uniformity in states' drinking ages, was within constitutional bounds. The Court found that the legislation was in pursuit of "the general welfare," and that the means chosen to do so were reasonable. The Court also held that the Twenty-first Amendment's limitations on spending power were not prohibitions on congressional attempts to achieve federal objectives indirectly. The five percent loss of highway funds was not unduly coercive.

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SOUTH DAKOTA v. DOLE. The Oyez Project at IIT Chicago-Kent College of Law. 01 October 2014. <http://www.oyez.org/cases/1980-1989/1986/1986_86_260>.
SOUTH DAKOTA v. DOLE, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1980-1989/1986/1986_86_260 (last visited October 1, 2014).
"SOUTH DAKOTA v. DOLE," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 1, 2014, http://www.oyez.org/cases/1980-1989/1986/1986_86_260.