Driver's Privacy Protection Act of 1994 (DPPA) regulated the disclosure of personal information contained in the records of DMVs.
Many states (SC included) would sell this information to private individuals.
The DPPA prohibited this practice and also prohibited private individuals from selling information they get from the DMV as well.
SC filed suit against US claiming that the DPPA violated the 10th and 11th amendments.
Procedural History:
SCOTUS found for U.S., held DPPA constitutional.
Issues:
Is the DPPA a violation of the 10th and 11th amendments of the Constitution?
Holding/Rule:
The DPPA is not a violation of the 10th and 11th amendments of the Constitution because …
It does not require the legislature to enact any laws (NY)
And does not require state officials to assist in the enforcement of federal statutes regulating private individuals (Printz).
Reasoning:
DPPA is valid use of the commerce power since the information is a good that is exchanged in interstate commerce.
SC argues that DPPA violates because it thrusts upon the states all of the day-to-day responsibility for administering its complex provisions and makes state officials unwilling implementors or federal policy (from NY and Printz)
However, this case is not governed by NY or Printz. It is governed by SC v. Baker because the DPPA does not require the legislature to enact any laws (NY) and does not require state officials to assist in the enforcement of federal statutes regulating private individuals (Printz).
There, upheld a statute that prohibited states from issuing unregistered bonds because the law "regulated state activities" rather than "seeking to control or influence the manner in which states regulate private parties."
Amending of statues or implementing new systems by state legislatures is an inevitable consequence of regulating a state activity and is not commandeering.
If a state wishes to engage in certain activity, it must take administrative and sometimes legislative action to comply with federal standards regulating such activity.
The DPPA applies to both the state gov't and individuals; no need to get into the question of whether Congress can pass statutes that regulate states exclusively.
