Reno v. Condon
528 U.S. 141 (2000)
- Congress enacted the Driver’s Privacy Protection Act of 1994 (DPPA), which established a regulatory scheme that restricted the States’ ability to disclose a driver’s personal information without the driver’s consent, after finding that many States sell such information.
- State departments of motor vehicles (DMVs) require drivers and automobile owners to provide personal information, as a condition of obtaining a driver’s license or registering an automobile.
- The DPPA conflicts with South Carolina law, under which information contained in the State’s DMV records is available to any person or entity that fills out a form listing the requester’s name and address and stating that the information will not be used for telephone solicitation.
- The Attorney General of South Carolina filed suit, arguing that the DPPA violated the 10th Amendment and the 11th Amendment.
- The Trial Court concluded that the DPPA was incompatible with the principles of federalism, granted summary judgment for the State, and permanently enjoined the DPPA’s enforcement against the State.
- The Appellate Court affirmed.
- The Appellate Court concluded that the DPPA violated the constitutional principles of federalism.
- The US Supreme Court reversed the Appellate Court.
- The US Supreme Court found that the DPPA is a constitutional exercise of Congress’s Interstate Commerce Clause power.
- The Court also found that the DPPA does not violate the 10th Amendment, because there are many other Federal regulations that require time and effort for compliance which are constitutional under the 10th Amendment.
- The Court found that the DPPA is a proper exercise of Congress’ regulation of interstate commerce under the Interstate Commerce Clause and doesn’t run afoul of federalism principles.
- The law “does not require the States in their sovereign capacity to regulate their own citizens. It does not require the South Carolina Legislature to enact any laws or regulations, and it does not require State officials to assist in the enforcement of Federal Statutes regulating private individuals.”