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Reno v. Condon

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2000 United States Supreme Court case
Reno v. Condon
Argued November 10, 1999
Decided January 12, 2000
Full case nameReno v. Condon
Citations528U.S.141 (more)
120 S. Ct. 666; 145L. Ed. 2d 587; 2000U.S. LEXIS 503
Case history
PriorSummary judgment granted, 972F. Supp.977 (D.S.C. 1997); affirmed, 155F.3d453 (4th Cir. 1998);cert. granted,526 U.S. 1111 (1999).
Holding
The DPPA did not run afoul of the federalism principles enunciated inNew York v. United States andPrintz v. United States, and was a valid exercise ofCongress' power under theCommerce 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 byunanimous
Laws applied
U.S. Const. amend. X

Reno v. Condon, 528 U.S. 141 (2000), was a case in which theSupreme Court of the United States upheld theDriver's Privacy Protection Act of 1994 (DPPA) against aTenth Amendment challenge.[1]

Facts and procedural history

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Statedepartments 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 (particularlydirect marketing andauto insurance companies) for significant revenues, and to preventstalkers 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 generalCharlie Condon, filed suit, alleging that the DPPA violates theTenth andEleventh Amendments to theUnited States Constitution. Concluding that the DPPA is incompatible with the principles offederalism inherent in the Constitution's division of power between the States and the Federal Government, theUnited States District Court for the District of South Carolina grantedsummary judgment for the State and permanentlyenjoined the DPPA's enforcement against the State and its officers,[3] andUnited States Court of Appeals for the Fourth Circuit affirmed.[4]Janet Reno petitioned to the United States Supreme Court for review.

Decision

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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 theCommerce 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 inNew York v. United States andPrintz v. United States did. Instead, Rehnquist analogized the DPPA to the statute at issue inSouth Carolina v. Baker, 485 U.S. 505 (1988), which prohibited States from issuing unregisteredbonds:

Like the statute at issue inBaker, 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 inNew York andPrintz.[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

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References

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  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.

External links

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Text ofReno v. Condon,528 U.S. 141 (2000) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)

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