Brief Fact Summary. South Carolina brought suit against United States Attorney General Reno, arguing that the Driver’s Privacy Protection Act of 1994 (“DPPA”) violated the Tenth Amendment’s limitation on the Federal Government’s power to regulate the states.
Synopsis of Rule of Law. The Tenth Amendment does not prevent the Federal Government from regulating the States as individual entities if it does not ask the States to enforce a federal program.
Issue. May Congress require State compliance with the DPPA?
Held. Yes. Appeals court ruling reversed and remanded. The DPPA does not require the states to regulate their own citizens. Neither does it require the South Carolina legislature to enact any laws or assist in the enforcement of federal statutes regulating private citizens. As the DPPA only restricts state government action, it cannot be said to commandeer state government in violation of the Tenth Amendment.
After listing section 2721(b)'s fourteen permissible purposes, Chief Justice Rehnquist equated authorized recipients under section 2721(c) with private persons who have obtained drivers personal information for one of the aforementioned permissible purposes to further disclose that information for any one of those purposes.View Full Point of Law