Brief Fact Summary. Appellant alleges that the federal withholding of a small percentage of highway funds to states allowing public possession or purchase of alcohol by individuals under 21 years is unconstitutional.
Synopsis of Rule of Law. Non-coercive financial incentives by Congress are a constitutional exercise of the taxing and spending power.
Thus, objectives not thought to be within Article I's enumerated legislative fields may nevertheless be attained through the use of the spending power and the conditional grant of federal funds.View Full Point of Law
Issue. May Congress withhold funds from states that do not maintain a 21 year old drinking age?
Held. Yes. Appeals court ruling affirmed. A withholding of a small amount of funds is not a coercive measure and a proper exercise of taxing and spending power.
Dissent. Justices William Brennan and Sandra Day O’Connor both dissent on the unrelated ground of the Twenty-first Amendment, which relegates regulation of alcohol sales to the states.
Discussion. Congress may put “strings” on funds disbursed to States, so long as the conditions are explicitly stated.