Reno v. Condon Case Brief

Facts of the case

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, Social Security number, and photograph, as a condition of obtaining a driver’s license or registering an automobile. Congress enacted the Driver’s Privacy Protection Act of 1994 (DPPA),which establishes a regulatory scheme that restricts the States’ ability to disclose a driver’s personal information without the driver’s consent, after finding that many States sell such information. 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, alleging the DPPA violated the Tenth and Eleventh Amendments. The District Court concluded that the DPPA was incompatible with the principles of federalism, granted summary judgement for the State, and permanently enjoined the DPPA’s enforcement against the State. In affirming, the Court of Appeals also concluded that the DPPA violated the constitutional principles of federalism.

Why is the case important?

South Carolina brought suit against United States Attorney General Reno, arguing that the Driver’s Privacy Protection Act of 1994 (“DPPA”) violated the Tenth Amendment’s limitation on the Federal Government’s power to regulate the states.

Question

May Congress require State compliance with the DPPA?

ANSWER

Yes. Appeals court ruling reversed and remanded. The DPPA does not require the states to regulate their own citizens. Neither does it require the South Carolina legislature to enact any laws or assist in the enforcement of federal statutes regulating private citizens. As the DPPA only restricts state government action, it cannot be said to commandeer state government in violation of the Tenth Amendment.

CONCLUSION

The court held the DPPA was a proper exercise of Congress’ authority to regulate interstate commerce because drivers’ information was an article of commerce and its sale or release into the interstate stream of business was sufficient to support congressional regulation. The court rejected respondents’ argument that the DPPA violated the principles of federalism contained in U.S. Const. amend. X since it did not require the South Carolina Legislature to enact any laws or regulations, and it did not require state officials to assist in the enforcement of federal statutes regulating private individuals.

  • Advocates: Charles Condon Columbia, South Carolina, argued the cause for respondents Seth P. Waxman Department of Justice, argued the cause for petitioners
  • Petitioner: Reno
  • Respondent: Condon
  • DECIDED BY:Rehnquist Court
  • Location: Congress
Citation: 528 US 141 (2000)
Argued: Nov 10, 1999
Decided: Jan 12, 2000
Reno v. Condon Case Brief