Reno v. Condon

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.[1]

Reno v. Condon
Argued November 10, 1999
Decided January 12, 2000
Full case nameReno v. Condon
Citations528 U.S. 141 (more)
120 S. Ct. 666; 145 L. Ed. 2d 587; 2000 U.S. LEXIS 503
Case history
PriorSummary judgment granted, 972 F. Supp. 977 (D.S.C. 1997); affirmed, 155 F.3d 453 (4th Cir. 1998); cert. granted, 526 U.S. 1111 (1999).
Holding
The DPPA did not run afoul of the federalism principles enunciated in New York v. United States and Printz v. United States, and was a valid exercise of Congress' power under the Commerce Clause.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinion
MajorityRehnquist, joined by unanimous
Laws applied
U.S. Const. amend. X

Facts and procedural history

State departments of motor vehicles (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,[2] Congress enacted the Driver's Privacy Protection Act of 1994, 18 U.S.C. §§ 27212725, 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,[3] and United States Court of Appeals for the Fourth Circuit affirmed.[4]

Decision

Chief Justice 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:

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.[5]

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.

gollark: The UK does those, I think, and seems to be doing fine lawyer and doctor-wise.
gollark: A convincing explanation I read of the everyone-has-to-go-to-college thing is that college degrees work as a signal to employers that you have some basic competence at listening independently, doing things for delayed gain later, sort of thing, more than providing any massively work-relevant skills, and it apparently got easier/more popular to get a degree over time, so the *lack* of one works as a signal that you *lack* those basic skills.
gollark: No idea.
gollark: Throwing money at a somewhat broken system can just perpetuate the somewhat broken system and cost a lot.
gollark: Oh, 30.

See also

References

  1. Reno v. Condon, 528 U.S. 141 (2000).
  2. Brief for the Petitioners, Reno v. Condon, 528 U.S. 141 (2000), No. 98-1464, at 5
  3. Condon v. Reno, 972 F. Supp. 977 (D.S.C. 1997).
  4. Condon v. Reno, 155 F.3d 453 (4th Cir. 1998).
  5. 528 U.S. at 151.

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