Reno v. Condon
Encyclopedia
Reno v. Condon, 528 U.S. 141
(2000), was a case in which the Supreme Court of the United States
upheld the Driver's Privacy Protection Act of 1994 (DPPA) against a Tenth Amendment
challenge.
(DMVs) require drivers and automobile owners to provide personal information, which may include a person's name, address, telephone number, vehicle description, Social Security number
, medical information, and photograph, as a condition of obtaining a driver's license or registering an automobile. Finding that many States sell this information to individuals and businesses (particularly direct marketing
and auto insurance
companies) for significant revenues, and to prevent stalkers from tracking their victims across state lines, Congress enacted the Driver's Privacy Protection Act of 1994, , which established a regulatory scheme to restrict the States' ability to disclose a driver's personal information without the driver's consent.
South Carolina, represented by South Carolina attorney general Charlie Condon
, filed suit, alleging that the DPPA violates the Tenth
and Eleventh Amendments
to the United States Constitution
. Concluding that the DPPA is incompatible with the principles of federalism inherent in the Constitution's division of power between the States and the Federal Government, the United States District Court for the District of South Carolina
granted summary judgment
for the State and permanently enjoined
the DPPA's enforcement against the State and its officers, and United States Court of Appeals for the Fourth Circuit
affirmed.
William Rehnquist
delivered the opinion of a unanimous Court. He began by explaining the terms of the DPPA and how it conflicted with South Carolina's statutes governing drivers' license information. He held that 1) the DPPA was an acceptable exercise of Congress' powers under the Commerce Clause
, because drivers' information was an "article of interstate commerce" within the terms of the Act, and 2) the DPPA did not "commandeer" state authority in the manner which the statutes involved in New York v. United States
and Printz v. United States
did. Instead, Rehnquist analogized the DPPA to the statute at issue in South Carolina v. Baker
, 485 U.S. 505 (1988), which prohibited States from issuing unregistered bonds
:
Finally, Rehnquist addressed South Carolina's argument that Congress could only regulate the individual states by means of laws of "general applicability", rather than directly targeting state governments for regulation. Instead of determining whether such "general applicability" is indeed a Constitutional requirement, Rehnquist merely pointed out that the DPPA was "generally applicable", because in addition to regulating the actions of state governments, it also regulated private persons who resold or redistributed drivers' information.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2000), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
upheld the Driver's Privacy Protection Act of 1994 (DPPA) against a Tenth Amendment
Tenth Amendment to the United States Constitution
The Tenth Amendment to the United States Constitution, which is part of the Bill of Rights, was ratified on December 15, 1791...
challenge.
Facts and procedural history
State departments of motor vehiclesDepartment of Motor Vehicles
In the United States of America, a Department of Motor Vehicles is a state-level government agency that administers vehicle registration and driver licensing. Similar departments exist in Canada...
(DMVs) require drivers and automobile owners to provide personal information, which may include a person's name, address, telephone number, vehicle description, Social Security number
Social Security number
In the United States, a Social Security number is a nine-digit number issued to U.S. citizens, permanent residents, and temporary residents under section 205 of the Social Security Act, codified as . The number is issued to an individual by the Social Security Administration, an independent...
, medical information, and photograph, as a condition of obtaining a driver's license or registering an automobile. Finding that many States sell this information to individuals and businesses (particularly direct marketing
Direct marketing
Direct marketing is a channel-agnostic form of advertising that allows businesses and nonprofits to communicate straight to the customer, with advertising techniques such as mobile messaging, email, interactive consumer websites, online display ads, fliers, catalog distribution, promotional...
and auto insurance
Vehicle insurance
Vehicle insurance is insurance purchased for cars, trucks, motorcycles, and other road vehicles. Its primary use is to provide financial protection against physical damage and/or bodily injury resulting from traffic collisions and against liability that could also arise therefrom...
companies) for significant revenues, and to prevent stalkers from tracking their victims across state lines, Congress enacted the Driver's Privacy Protection Act of 1994, , which established a regulatory scheme to restrict the States' ability to disclose a driver's personal information without the driver's consent.
South Carolina, represented by South Carolina attorney general Charlie Condon
Charlie Condon
Charlie Condon is a former Attorney General of South Carolina, and served as the first Chairman of the Republican Attorneys General Association. He also served as Chairman of John McCain's presidential campaign in South Carolina. He currently is an in private practice in Mt. Pleasant , South...
, filed suit, alleging that the DPPA violates the Tenth
Tenth Amendment to the United States Constitution
The Tenth Amendment to the United States Constitution, which is part of the Bill of Rights, was ratified on December 15, 1791...
and Eleventh Amendments
Eleventh Amendment to the United States Constitution
The Eleventh Amendment to the United States Constitution, which was passed by the Congress on March 4, 1794, and was ratified on February 7, 1795, deals with each state's sovereign immunity. This amendment was adopted in order to overrule the U.S. Supreme Court's decision in Chisholm v...
to the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
. Concluding that the DPPA is incompatible with the principles of federalism inherent in the Constitution's division of power between the States and the Federal Government, the United States District Court for the District of South Carolina
United States District Court for the District of South Carolina
The United States District Court for the District of South Carolina is the federal district court whose jurisdiction is the state of South Carolina...
granted summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
for the State and permanently enjoined
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
the DPPA's enforcement against the State and its officers, and United States Court of Appeals for the Fourth Circuit
United States Court of Appeals for the Fourth Circuit
The United States Court of Appeals for the Fourth Circuit is a federal court located in Richmond, Virginia, with appellate jurisdiction over the district courts in the following districts:*District of Maryland*Eastern District of North Carolina...
affirmed.
Decision
Chief JusticeChief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
delivered the opinion of a unanimous Court. He began by explaining the terms of the DPPA and how it conflicted with South Carolina's statutes governing drivers' license information. He held that 1) the DPPA was an acceptable exercise of Congress' powers under the Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
, because drivers' information was an "article of interstate commerce" within the terms of the Act, and 2) the DPPA did not "commandeer" state authority in the manner which the statutes involved in New York v. United States
New York v. United States (1992)
New York v. United States, 505 U.S. 144 was a decision of the United States Supreme Court. Justice Sandra Day O'Connor, writing for the majority, found that the "Take Title" provision of the Low-Level Radioactive Waste Policy Amendments Act of 1985 exceeded Congress's power under the Commerce...
and Printz v. United States
Printz v. United States
Printz v. United States, 521 U.S. 898 , was a United States Supreme Court ruling that established the unconstitutionality of certain interim provisions of the Brady Handgun Violence Prevention Act.-The Gun Control Act of 1968:...
did. Instead, Rehnquist analogized the DPPA to the statute at issue in South Carolina v. Baker
South Carolina v. Baker
South Carolina v. Baker, 485 U.S. 505 , is a case in which the Supreme Court of the United States ruled that section 310 of the Tax Equity and Fiscal Responsibility Act of 1982 does not violate the Tenth Amendment to the United States Constitution...
, 485 U.S. 505 (1988), which prohibited States from issuing unregistered bonds
Bond (finance)
In finance, a bond is a debt security, in which the authorized issuer owes the holders a debt and, depending on the terms of the bond, is obliged to pay interest to use and/or to repay the principal at a later date, termed maturity...
:
Like the statute at issue in Baker , the DPPA does not require the States in their sovereign capacity to regulate their own citizens. The DPPA regulates the States as the owners of databases. 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. We accordingly conclude that the DPPA is consistent with the constitutional principles enunciated in New York and Printz.
Finally, Rehnquist addressed South Carolina's argument that Congress could only regulate the individual states by means of laws of "general applicability", rather than directly targeting state governments for regulation. Instead of determining whether such "general applicability" is indeed a Constitutional requirement, Rehnquist merely pointed out that the DPPA was "generally applicable", because in addition to regulating the actions of state governments, it also regulated private persons who resold or redistributed drivers' information.
See also
- List of United States Supreme Court cases, volume 529
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume