Facts: Congress tried to use their spending power to get
state governments to raise the drinking age to 21. Congress passed a law that withheld a certain
percentage of federal funds to any state with a drinking age lower than
Issue: Does Congress have the power under Article I and the Twenty-First
Amendment to “encourage”
Rule: (1) Congress’s use of the spending power must be in pursuit of the “general welfare”. (2) If Congress conditions the States’ receipt of federal funds, it must do so unambiguously. (3) Congress can’t place conditions on funding if those conditions are not related to “particular national projects or programs”. (4) Congress cannot use its spending power to induce states to perform actions that are unconstitutional.
Analysis: The Court says that
O’Connor disagrees that the condition is closely related to the purpose for which the funds are expended. O’Connor says that underage drinking is not sufficiently closely related to interstate highway construction.
O’Connor also thinks that the law is an exercise of regulatory power rather than spending power. O’Connor thinks that the Twenty-First Amendment gives this power solely to the states.
Conclusion: The judgment of the Court of Appeals is affirmed and the action of Congress is found to be constitutional.