Kansas v. United States
214 F.3d 1196 (2000)

  • 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 other States.
    • 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' sovereignty.
    • 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 Process.
    • 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 general welfare.
      • 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 close enough.
      • 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 IV-D compulsory.