In an effort to get people off
welfare, the Federal government passed the Personal Responsibility and
Work Opportunity Reconciliation Act (PRWORA).
Part of PRWORA had to do with changes to the way the States
were to administrate their Child Support Enforcement Program (IV-D) (42 U.S.C. §§651-669).
IV-D basically gave Federal money to the States
so that that States could provide child support services to people on welfare.
PRWORA added a lot of administrative burdens on the
States. They had to keep databases of who was required to pay child
support, and cross-reference them with other States' databases
to find deadbeats.
The idea was that the
database would allow courts to easily find deadbeats that had moved to
Note that States were not
required to implement IV-D, but
if they didn't, they'd lose a lot of welfare money that the Federal
government gave them.
Kansas was getting $130M a
year at the time.
Kansas sued the Federal
government, arguing that the new IV-D
rules were too expensive to administer and encroached upon Kansas'
Kansas argued that while
they didn't have to take the
money, the Federal government was giving so much that they couldn't
afford to opt out of the system.
It also violated the Spending
Clause, the 10th
Amendment, the privacy rights of citizens, and violated Due
The Federal government
argued that they had the power to enact the IV-D requirements under the Spending Clause.
The Trial Court dismissed the
claim. Kansas appealed.
The Appellate Court affirmed.
The Appellate Clause found
that when the Federal government is exercising the Spending Clause, the conditions on State receipt of Federal
funds must be:
Be in the pursuit of the
Be unambiguous so States
know the consequences of their decision not to participate.
Have conditions related to
the Federal interest in the program.
Have no independent
constitutional bar to the conditions.
See South Dakota v. Dole (483 U.S. 203 (1987))
Kansas argued that the IV-D conditions weren't sufficiently related to
the receipt of the funds, but the Court disagreed and found they were
Because assisting people in
establishing paternity and collecting child support can reduce a
family's dependence on welfare.
In Dole, the US Supreme Court noted a fifth
condition; "In some circumstances the financial inducement offered
by Congress might be so coercive as to pass the point at which pressure
turns into compulsion." However the Court felt that the money the
Federal government was offering in this case didn't make participation in