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."