South Dakota

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Moi University *

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Law

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Nov 24, 2024

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1 South Dakota Versus Dole Decision Names School Course Instructor Date

2 South Dakota versus Dole Decision The question of the legitimacy of the United States federal government's authority to impose specific requirements on states in order to receive federal funds was a central issue in the U.S. Supreme Court case South Dakota versus Dole (1987). The legal action presented a challenge to the National Minimum Drinking Age Act of 1984, a federal legislation that imposed a uniform minimum drinking age of 21 across the nation. Failure to comply with this requirement would result in states forfeiting federal transportation funding. 1 The majority opinion authored by Chief Justice Rehnquist upheld the legitimacy of the act, while the dissenting opinion of Justice Sandra Day O'Connor's centered on the limitations it imposed on the rights of individual states. Modes of Interpretation Textualism : The majority decision primarily employs a textualist methodology in its interpretation of the Constitution. Chief Justice Rehnquist claimed that the Spending Clause confers upon Congress extensive latitude to allocate funds for the overall well-being of the nation, and that linking the disbursement of federal resources to states' adherence to specific requirements aligns with this authority. Pragmatism : The result made by the majority can also be interpreted as pragmatic due to its recognition of the federal government's valid concern in advancing traffic safety and mitigating alcohol-related incidents. This objective might be effectively pursued through the establishment of a consistent drinking age. Judicial Precedent : The majority ruling in question drew upon established legal precedents, such as the instances of Steward Machine Co. v. Davis (1937) and Helvering v. Davis (1937), to bolster the argument for the legitimacy of Congress's spending restrictions. Enumerated Legislature Powers 1 Baker, Lynn A. "Twenty-Year Legacy of South Dakota v. Dole." SDL Rev. 52 (2007): 468.

3 In this instance, the legislative branch is exercising an enumerated power recognized by the Constitution, namely the "Spending Clause" of Article I, Section 8, Clause 1 of the United States Constitution. 2 This provision grants Congress the authority to levy taxes and spend the revenue for the common good. Impact on States' Rights In South Dakota v. Dole, the Supreme Court ruled that individual states have the authority to determine their own drinking age policies. 3 While it was previously up to individual states to set the drinking age within their borders, the federal government was able to exert some indirect influence through the use of conditions attached to the acceptance of federal funding. The precedent set by the decision could eventually lead to a shift in power from the federal government to the states by incentivizing the adoption of specific legislation or policies by linking them to financing. Agreement with the Majority Opinion Whether or not you agree with the majority view depends on how you read the Spending Clause and the larger ideas of federalism in the Constitution. The judgment by the majority showed the government's ability to indirectly address national issues through conditional funding. Using this method, Congress can encourage state conformity without imposing mandatory compliance. However, issues occur when these circumstances approach coercion and may limit the autonomy of nations in determining their own policy preferences. From my vantage point, the majority conclusion in South Dakota v. Dole is consistent with the Constitution and the fundamental pliability that federalism necessitates. However, care is still needed to prevent the federal government from infringing too heavily on state 2 Meierhenry, M. (2007). The History of South Dakota v. Dole. SDL Rev. , 52 , 454. 3 Melone, M. A. (2019). Murphy v. NCAA & South Dakota v. Wayfair, Inc.: The Court's Anticommandeering Jurisprudence May Preclude Congressional Action with Respect to Sales Taxes on Internet Sales. Drake L. Rev. , 67 , 413.

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4 sovereignty. It's important to keep an eye on this judgment because it sets a precedent for the federal government's capacity to influence numerous state policies through conditional financing, and while the decision was made to address a real concern (highway safety), it could lead to an excess of federal power if not monitored closely. In conclusion, when it comes to conditional spending, the Supreme Court's decision in South Dakota v. Dole demonstrated the fine line that must be walked between federal power and states' rights. The case made people wonder how much authority the federal government has and whether or not it should infringe on state authority. Justice O'Connor's dissenting opinion and the majority decision's interpretation methodology show two different takes on how much power the federal government should have. As a result of the ruling, it became clear how critical it is to strike a balance between federal and state power in order to effectively solve national issues.

5 Bibliography Baker, L. A. (2007). Twenty-Year Legacy of South Dakota v. Dole. SDL Rev. , 52 , 468. https://heinonline.org/hol-cgi-bin/get_pdf.cgi? handle=hein.journals/sdlr52&section=25 . Meierhenry, M. (2007). The History of South Dakota v. Dole. SDL Rev. , 52 , 454. https://heinonline.org/hol-cgi-bin/get_pdf.cgi? handle=hein.journals/sdlr52&section=22 . Melone, M. A. (2019). Murphy v. NCAA & South Dakota v. Wayfair, Inc.: The Court's Anticommandeering Jurisprudence May Preclude Congressional Action with Respect to Sales Taxes on Internet Sales. Drake L. Rev. , 67 , 413. https://heinonline.org/hol- cgi-bin/get_pdf.cgi?handle=hein.journals/drklr67&section=16 .

South Dakota

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