From Wikipedia, the free encyclopedia
2000 United States Supreme Court case
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]
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.
§§ 2721 –
2725 , 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]
Janet Reno petitioned to the United States Supreme Court for review.
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.
See also
References
External links
Text of Reno v. Condon ,
528
U.S. 141 (2000) is available from:
Cornell
CourtListener
Findlaw
Google Scholar
Justia
Library of Congress
Oyez (oral argument audio)
Dormant Commerce Clause
Brown v. Maryland (1827)
Willson v. Black-Bird Creek Marsh Co. (1829)
Cooley v. Board of Wardens (1852)
Wabash, St. Louis & Pacific Railway Co. v. Illinois (1886)
Swift & Co. v. United States (1905)
George W. Bush & Sons Co. v. Malloy (1925)
Baldwin v. G.A.F. Seelig, Inc. (1935)
Edwards v. California (1941)
Southern Pacific Co. v. Arizona (1945)
Dean Milk Co. v. City of Madison (1951)
Miller Bros. Co. v. Maryland (1954)
Bibb v. Navajo Freight Lines, Inc. (1959)
National Bellas Hess v. Illinois (1967)
Pike v. Bruce Church, Inc. (1970)
Hughes v. Alexandria Scrap Corp. (1976)
Complete Auto Transit, Inc. v. Brady (1977)
Hunt v. Washington State Apple Advertising Commission (1977)
City of Philadelphia v. New Jersey (1978)
Exxon Corp. v. Governor of Maryland (1978)
Reeves, Inc. v. Stake (1980)
Kassel v. Consolidated Freightways Corp. (1981)
Sporhase v. Nebraska ex rel. Douglas (1982)
White v. Mass. Council of Construction Employers (1983)
South-Central Timber Development, Inc. v. Wunnicke (1984)
Maine v. Taylor (1986)
Healy v. Beer Institute, Inc. (1989)
Quill Corp. v. North Dakota (1992)
Chemical Waste Management, Inc. v. Hunt (1992)
Oregon Waste Systems, Inc. v. Department of Environmental Quality of Oregon (1994)
C&A Carbone, Inc. v. Town of Clarkstown (1994)
West Lynn Creamery, Inc. v. Healy (1994)
Granholm v. Heald (2005)
United Haulers Ass'n v. Oneida-Herkimer Solid Waste Management Authority (2007)
Department of Revenue of Kentucky v. Davis (2008)
Comptroller of the Treasury of Maryland v. Wynne (2015)
South Dakota v. Wayfair, Inc. (2018)
Tennessee Wine and Spirits Retailers Assn. v. Thomas (2019)
National Pork Producers Council v. Ross (2023)
Others
Copyright Act of 1790
Patent Act of 1793
Patent infringement case law
Patentability case law
Copyright Act of 1831
Copyright Act of 1870
Sherman Antitrust Act of 1890
International Copyright Act of 1891
Copyright Act of 1909
Patent misuse case law
Clayton Antitrust Act of 1914
Lanham Act
Inwood Laboratories, Inc. v. Ives Laboratories, Inc. (1982)
San Francisco Arts & Athletics, Inc. v. United States Olympic Committee (1987)
Two Pesos, Inc. v. Taco Cabana, Inc. (1992)
Qualitex Co. v. Jacobson Products Co. (1995)
College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board (1999)
Cooper Industries, Inc. v. Leatherman Tool Group, Inc. (2001)
TrafFix Devices, Inc. v. Marketing Displays, Inc. (2001)
Dastar Corp. v. Twentieth Century Fox Film Corp. (2003)
Moseley v. V Secret Catalogue, Inc. (2003)
Lexmark International, Inc. v. Static Control Components, Inc. (2014)
POM Wonderful LLC v. Coca-Cola Co. (2014)
Matal v. Tam (2017)
Iancu v. Brunetti (2019)
Romag Fasteners, Inc. v. Fossil, Inc. (2020)
Copyright Act of 1976
Zacchini v. Scripps-Howard Broadcasting Co. (1977)
Sony Corp. of America v. Universal City Studios, Inc. (1984)
Mills Music, Inc. v. Snyder (1985)
Harper & Row v. Nation Enterprises (1985)
Community for Creative Non-Violence v. Reid (1989)
Stewart v. Abend (1990)
Feist Publications, Inc., v. Rural Telephone Service Co. (1991)
Fogerty v. Fantasy, Inc. (1994)
Campbell v. Acuff-Rose Music, Inc. (1994)
Lotus Dev. Corp. v. Borland Int'l, Inc. (1996)
Quality King Distributors Inc., v. L'anza Research International Inc. (1998)
Feltner v. Columbia Pictures Television, Inc. (1998)
New York Times Co. v. Tasini (2001)
Eldred v. Ashcroft (2003)
MGM Studios, Inc. v. Grokster, Ltd. (2005)
Reed Elsevier, Inc. v. Muchnick (2010)
Golan v. Holder (2012)
Kirtsaeng v. John Wiley & Sons, Inc. (2013)
Petrella v. Metro-Goldwyn-Mayer, Inc. (2014)
American Broadcasting Cos., Inc. v. Aereo, Inc. (2014)
Star Athletica, LLC v. Varsity Brands, Inc. (2017)
Fourth Estate Public Benefit Corp. v. Wall-Street.com (2019)
Rimini Street Inc. v. Oracle USA Inc. (2019)
Allen v. Cooper (2020)
Georgia v. Public.Resource.Org, Inc. (2020)
Other
copyright cases Other
patent cases
Continental Paper Bag Co. v. Eastern Paper Bag Co. (1908)
Minerals Separation, Ltd. v. Hyde (1916)
United States v. General Electric Co. (1926)
United States v. Univis Lens Co. (1942)
Altvater v. Freeman (1943)
Sinclair & Carroll Co. v. Interchemical Corp. (1945)
Funk Bros. Seed Co. v. Kalo Inoculant Co. (1948)
Great Atlantic & Pacific Tea Co. v. Supermarket Equipment Corp. (1950)
Graver Tank & Manufacturing Co. v. Linde Air Products Co. (1950)
Aro Manufacturing Co. v. Convertible Top Replacement Co. (1961)
Compco Corp. v. Day-Brite Lighting, Inc. (1964)
Wilbur-Ellis Co. v. Kuther (1964)
Brulotte v. Thys Co. (1964)
Walker Process Equipment, Inc. v. Food Machinery & Chemical Corp. (1965)
Graham v. John Deere Co. (1966)
United States v. Adams (1966)
Brenner v. Manson (1966)
Lear, Inc. v. Adkins (1969)
Anderson's-Black Rock, Inc. v. Pavement Salvage Co. (1969)
Zenith Radio Corp. v. Hazeltine Research, Inc. (1971)
Gottschalk v. Benson (1972)
United States v. Glaxo Group Ltd. (1973)
Dann v. Johnston (1976)
Sakraida v. Ag Pro Inc. (1976)
Parker v. Flook (1978)
Diamond v. Chakrabarty (1980)
Diamond v. Diehr (1981)
Bonito Boats, Inc. v. Thunder Craft Boats, Inc. (1989)
Eli Lilly & Co. v. Medtronic, Inc. (1990)
Markman v. Westview Instruments, Inc. (1996)
Warner-Jenkinson Co. v. Hilton Davis Chemical Co. (1997)
Pfaff v. Wells Electronics, Inc. (1998)
Dickinson v. Zurko (1999)
Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank (1999)
J. E. M. Ag Supply, Inc. v. Pioneer Hi-Bred International, Inc. (2001)
Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co. (2002)
Merck KGaA v. Integra Lifesciences I, Ltd. (2005)
eBay Inc. v. MercExchange, L.L.C. (2006)
Illinois Tool Works Inc. v. Independent Ink, Inc. (2006)
LabCorp v. Metabolite, Inc. (2006)
MedImmune, Inc. v. Genentech, Inc. (2007)
KSR International Co. v. Teleflex Inc. (2007)
Microsoft Corp. v. AT&T Corp. (2007)
Quanta Computer, Inc. v. LG Electronics, Inc. (2008)
Bilski v. Kappos (2010)
Global-Tech Appliances, Inc. v. SEB S.A. (2011)
Stanford University v. Roche Molecular Systems, Inc. (2011)
Microsoft Corp. v. i4i Ltd. Partnership (2011)
Mayo Collaborative Services v. Prometheus Laboratories, Inc. (2012)
Kappos v. Hyatt (2012)
Bowman v. Monsanto Co. (2013)
Gunn v. Minton (2013)
Association for Molecular Pathology v. Myriad Genetics, Inc. (2013)
FTC v. Actavis, Inc. (2013)
Alice Corp. v. CLS Bank International (2014)
Akamai Techs., Inc. v. Limelight Networks, Inc. (2014)
Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc. (2015)
Kimble v. Marvel Entertainment, LLC (2015)
Apple Inc. v. Samsung Electronics Co. (2016)
TC Heartland LLC v. Kraft Foods Group Brands LLC (2017)
Peter v. NantKwest, Inc. (2019)
Other
trademark cases
Forced participation or commandeering Commerce clause Others