State of Nevada v. Skinner

884 F.2d 445
CourtCourt of Appeals for the Ninth Circuit
DecidedAugust 31, 1989
Docket88-2486
StatusPublished
Cited by8 cases

This text of 884 F.2d 445 (State of Nevada v. Skinner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Nevada v. Skinner, 884 F.2d 445 (9th Cir. 1989).

Opinion

884 F.2d 445

58 USLW 2156

The STATE OF NEVADA, Plaintiff-Appellant,
v.
Samuel K. SKINNER* Secretary of Transportation
for the United States; and A.J. Horner, Chief of
the Nevada Division of the Federal
Highway Administration,
Defendants-Appellees.

No. 88-2486.

United States Court of Appeals,
Ninth Circuit.

Argued and Submitted June 29, 1989.
Decided Aug. 31, 1989.

Brian McKay, Atty. Gen. of Nevada, Carson City, Nev., Brooke A. Nielsen, Chief Deputy Atty. Gen., Nevada Dept. of Transp., Carson City, Nev., for plaintiff-appellant.

Shirley Smith, U.S. Attys. Office, Reno, Nev., Sandra M. Schraibman, Leonard Schaitman, and Robert V. Zener, Dept. of Justice, Washington, D.C., for defendants-appellees.

Appeal from the United States District Court for the District of Nevada.

Before TANG, REINHARDT and WIGGINS, Circuit Judges.

REINHARDT, Circuit Judge:

This case raises the first challenge to the constitutionality of the national speed limit. The constitutional question is a fundamental one involving the distribution of powers between the federal government and the states. After fully considering the relevant issues, we decide in favor of the federal government and uphold the national speed limit.

In 1916, Congress enacted the Federal Aid Highway Act ("the Highway Act"). Under the Highway Act, the Federal Government provides funds directly to the States for maintenance of their highways. In 1973, Congress passed the Emergency Highway Energy Conservation Act which was permanently codified as a part of the Highway Act. It required the States as a precondition to receiving federal funds to post a maximum speed limit of 55 miles per hour (mph) on all highways, including secondary roads that were not directly part of the interstate network. While Congress did not order the States to conform their speed limits to the new national standard, it imposed a draconian consequence for noncompliance, denial of all future federal highway grants.

The events giving rise to the current controversy began in June of 1985. In that month, the Nevada state legislature passed legislation increasing the speed limit on Nevada highways. See 1985 Nev.Stats. 678 Sec. 3, codified at Nev.Rev.Stats. Sec. 484.369 (1985). The new statute, inter alia, permitted the Nevada Department of Transportation (Nevada DOT) to post a limit of 70 mph. Because of the state's concern over the reaction of the federal government, the statute contained a self-executing sunset provision. It required the 70 mph limit to be lowered to the national speed limit if and when federal officials threatened to cut off state highway aid.

Section 484.369 went into effect on July 1, 1986. Acting pursuant to their statutory authority, officials of the Nevada DOT established a 70 mph speed limit on a thirty-three mile stretch of Interstate Highway 80 (I-80) between the East Farley Interchange and the I-80 junction with I-95 west of Lovelock, Nevada at 7:30 a.m. on July 1. The federal government responded with alacrity. Approximately sixty seconds after the state's action, appellee A.J. Horner, Chief of the Nevada Division of the Federal Highway Administration, formally advised the Nevada DOT that all future federal funds for state highways would be withheld unless the state reduced the I-80 speed limit so as to comply with the national speed limit. Concurrent with this notice, the 70 mph limit expired by its own terms.1

Nevada sued in United States District Court for injunctive and declaratory relief against enforcement of 23 U.S.C. Sec. 154. The state contended that because the Highway Act threatened withholding of approximately 95% of all of Nevada's highway funds, it had no real choice but to comply with the national speed limit provisions. Consequently, Nevada argued, the national limit violated the "coercion" limitation on the Federal Government's Spending Power. The district court rejected this argument and ordered summary judgment for the United States. Nevada appealed, and we affirm.

I. The Coercion Test in the Abstract

Article I specifically grants the Spending and Taxing Powers to Congress. "The Congress shall have Power To lay and collect Taxes, Duties, Imposts, and Excises, to pay the Debts and provide for the common Defence and general Welfare of the United States." Art. I, Sec. 8, cl. 1. Pursuant to this authority, Congress may condition the receipt of funds, by states or others, on compliance with federal directives. The Supreme Court has clearly, and repeatedly, declared that "Congress may further broad policy objectives by conditioning receipt of federal moneys upon compliance by the recipient with federal statutory and administrative directives." South Dakota v. Dole, 483 U.S. 203, 107 S.Ct. 2793, 2796, 97 L.Ed.2d 171 (1987) (quoting Fullilove v. Klutznick, 448 U.S. 448, 474, 100 S.Ct. 2758, 2772, 65 L.Ed.2d 902 (1980) (opinion of Burger, C.J.)). Moreover, Congress frequently, and with an almost unblemished record of success,2 has under its spending authority promulgated legislation in pursuit of the general welfare that reaches beyond its other enumerated Constitutional powers. See South Dakota v. Dole, 483 U.S. 203, 107 S.Ct. 2793, 2796, 97 L.Ed.2d 171 (1987) (collecting cases).

There are, however, limits upon the scope of the Spending Power. The Supreme Court has articulated at least four such restrictions. First, the exercise of the spending power must be in pursuit of the general welfare. See Oklahoma v. Civil Service Comm'n, 330 U.S. 127, 67 S.Ct. 544, 91 L.Ed. 794 (1947); Helvering v. Davis, 301 U.S. 619, 640, 57 S.Ct. 904, 908, 81 L.Ed. 1307 (1937). Second, the conditions on receipt of federal funds must be reasonably related to the articulated goal. South Dakota v. Dole, 107 S.Ct. at 2796. Third, Congress' intent to condition funds on a particular action must be authoritative and unambiguous, "enabl[ing] the States to exercise their choice knowingly, cognizant of the consequences of their participation." Pennhurst State School and Hospital v. Halderman, 451 U.S. 1, 17, 101 S.Ct. 1531, 1540, 67 L.Ed.2d 694 (1981). Fourth, the federal legislation may be invalid if an independent constitutional provision bars Congressional actions. The independent constitutional bar rule "stands for the unexceptionable proposition that the power may not be used to induce the States to engage in activities that would themselves be unconstitutional." South Dakota v. Dole, 107 S.Ct. at 2798.

Nevada does not seriously rely on any of these restrictions.3 Instead, it bases its claim on the indistinct coercion limitation first articulated in Steward Machine Co. v. Davis, 301 U.S. 548, 590, 57 S.Ct. 883, 893, 81 L.Ed.

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884 F.2d 445, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-nevada-v-skinner-ca9-1989.