New York v. United States - Case Summary and Case Brief (2024)

Following is the case brief for New York v. United States, 505 U.S. 144 (1992)

Case Summary of New York v. United States:

  • The Low-Level Radioactive Waste Policy Amendments Act of 1985 included three incentive provisions to encourage states to address the shortage of waste disposal sites.
  • New York State, and two counties, sought a declaratory judgment stating that the Act’s three incentive provisions were inconsistent with the Tenth Amendment and the Guarantee Clause of the Constitution.
  • The District Court dismissed the case, and the Court of Appeals affirmed.
  • The Supreme Court affirmed in part and reversed in part. It held that the first two provisions of the Act were proper uses of Congress’s Spending and Commerce powers. However, the third provision (which forced states to take possession of the waste within its borders) violated state sovereignty and, thus, the Tenth Amendment.

New York v. United StatesCase Brief

Statement of the Facts:

Congress passed the Low-Level Radioactive Waste Policy Amendments Act of 1985 to address the increasing shortage of disposal sites for low-level radioactive waste in 31 states. The Act essentially provides incentives so states will dispose of waste generated within their borders. Three such incentives were at issue in this matter.

  1. Monetary incentives: Congress conditioned grants to states that achieved certain milestones.
  2. Access incentives: Access to disposal sites would be gradually limited if a state wishing to dispose of waste did not meet federal deadlines.
  3. Take-title provision: A state that fails to dispose of all internally-created waste must take ownership of that waste and be held liable to the waste generator if the state does not take timely possession.

The State of New York, which generates a large amount of the nation’s low-level radioactive waste, believed that the Act violated, among other things, the Tenth Amendment of the Constitution.

Procedural History:

The State of New York, and two of its counties, sued in Federal District Court for a judgment declaring that the Act was inconsistent with the Tenth Amendment and the Guarantee Clause in Article IV of the Constitution. The District Court dismissed the complaint. The Second Circuit Court of Appeals affirmed the dismissal. The Supreme Court agreed to hear the case.

Issue and Holding:

Do any of the three incentive provisions of theLow-Level Radioactive Waste Policy Amendments Act of 1985 violate the Constitution? Yes. The take-title provision is inconsistent with the Tenth Amendment.

Judgment:

The judgment of the Second Circuit Court of Appeals is affirmed in part and reversed in part.

Rule of Law or Legal Principle Applied:

While the Constitution gives Congress substantial power to encourage the states to enforce federal law with incentives, it does not give the power to compel states to enforce federal law.

Reasoning:

  • The difference between federal encouragement and coercion.

Congress cannot simply compel a state to enforce a federal regulatory program. It would be unfair to do so because state officials would bear the brunt of public disapproval for something the federal government coerced the state to do. Congress can, however, use the Spending Power and the Commerce Clause to encourage states to make certain policy choices consistent with a federal program.

  • The take-title provision is an unconstitutional intrusion into state sovereignty.

In this case, the first two incentives (monetary and access incentives) are proper applications of Congress’s Spending and Commerce powers. The take-title provision, however, runs afoul of the boundary between federal and state power. The provision moves from encouragement to coercion. The only “choice” states have with the take-title provision is either to take ownership of waste, or regulate in accordance with federal direction. It, therefore, encroaches on state sovereignty in violation of the Tenth Amendment.

  • Severability and the Guarantee Clause.

Having found the take-title provision unconstitutional, the Court determined that the provision is severable from the rest of the Act. Further, the Court declined to make a determination with regard to New York’s claim under the Guarantee Clause.

Concurring and Dissenting Opinion (White):

The Court mischaracterized the issue in this case by failing to note that the states invited federal intervention that resulted in the Act. It also misanalyzed the issue it resolved, and neglected to appreciate the public policy implications of finding the take-title provision unconstitutional. All three provisions should have been deemed constitutional.

Concurring and Dissenting Opinion (Stevens):

The idea that Congress does not have the power to command the states to implement an Act of Congress is not correct. The take-title provision is within Congress’s power to impose on the states.

Significance:

New York v. United Statescenterson the notion of federalism. The debate presented in this case shows the difficulty in finding the line where federal power spills over into an intrusion on state sovereignty. Indeed, the extent to which this country is viewed as a group of sovereign states vs. one unified country continues to animate our legal discussion today.

Student Resources:

https://supreme.justia.com/cases/federal/us/505/144/case.html

https://www.oyez.org/cases/1991/91-543

New York v. United States - Case Summary and Case Brief (2024)

FAQs

New York v. United States - Case Summary and Case Brief? ›

United States is a case decided on June 19, 1992, by the United States Supreme Court holding that the federal government does not have the authority to force a state to enact specific laws. The case concerned whether the federal government could regulate state waste management.

What was the significance of the New York v United States case? ›

United States, 505 U.S. 144 (1992) The federal government cannot commandeer a state into enacting a certain law. The Low-Level Radioactive Waste Policy Amendments Act of 1985 resulted from a plan developed by the National Governors' Association.

What was the decision in New York Times Co v United States simple summary? ›

Often referred to as the “Pentagon Papers” case, the landmark Supreme Court decision in New York Times Co. v. United States, 403 U.S. 713 (1971), defended the First Amendment right of free press against prior restraint by the government.

Who won the case of New York v United States? ›

majority opinion by Sandra Day O'Connor. In a 6-3 decision, the Court upheld two of the three provisions of the Act under review, reasoning that Congress had the authority under the Commerce Clause to use financial rewards and access to disposal sites as incentives for state waste management.

What led to the New York Times v United States case? ›

Daniel Ellsberg was a part of a top secret study conducted by the Department of Defense about the U.S. involvement in the Vietnam War. Ellsberg leaked the study to a New York Times reporter, Neil Sheehan, who published part of the leaked information on the New York Times Sunday edition June 13, 1971.

What was the big idea of The New York Times v United States case? ›

The Government's power to censor the press was abolished so that the press would remain forever free to censure the Government. The press was protected so that it could bare the secrets of the government and inform the people. Only a free and unrestrained press can effectively expose deception in government.

What was the significance of The New York Times v United States quizlet? ›

This case is significant as the ruling made it possible for The New York Times and The Washington Post newspapers to publish the then-classified Pentagon Papers without risk of government censorship or punishment.

Which best describes according to the ruling in New York Times v. United States? ›

According to the ruling in New York Times v. United States, which best describes what the government had to prove for its censorship of the New York Times to have been acceptable? The articles would have had to indisputably threaten national security.

What was the decision in New York Times v Sullivan simple summary? ›

The decision established the important principle that the First Amendment guarantees of freedom of speech and press may protect libelous words about a public official in order to foster vigorous debate about government and public affairs.

Why did the Supreme Court rule in favor of the students who wore armbands? ›

The court found that the First Amendment applied to public schools, and school officials could not censor student speech unless it disrupted the educational process. Because wearing a black armband was not disruptive, the court held that the First Amendment protected the right of students to wear them.

How did the Supreme Court rule on the case against New York Times? ›

Decision: The United States Supreme Court unanimously ruled in favor of the newspaper. The Court said the right to publish all statements is protected under the First Amendment.

Which policy amendment was disputed in New York v. United States in 1992? ›

Petitioners, New York State andtwo of its counties, filed this suit against the United States, seeking a declaratory judgment that, inter alia, the three incentives provisions are inconsistent with the Tenth Amendment--which declares that "powers not delegated to the United States by the Constitution, nor prohibited by ...

What was the Supreme Court decision on New York? ›

On June 23, the Supreme Court of the United States handed down its decision in New York State Rifle and Pistol Association v. Bruen, overturning a New York gun safety law. The Court ruled that New York's law requiring a license to carry concealed weapons in public places is unconstitutional.

What did New York v United States do? ›

New York v. United States established that the federal government cannot compel states to enact certain laws.

Which statement accurately summarizes the impact of the New York Times Co. v. United States 1971 decision? ›

Final answer: The New York Times Co. v. United States (1971) decision limited the federal government's power to censor free speech or the publication of classified information.

What did the Pentagon Papers say? ›

The Pentagon Papers revealed that the United States had expanded its war with the bombing of Cambodia and Laos, coastal raids on North Vietnam, and Marine Corps attacks, none of which had been reported by the American media.

What was the significance of the New York v Miln case? ›

Miln established that states could enact regulations to protect their citizens. The decision in this case ruled that the state of New York could regulate certain commercial activities without violating the Commerce Clause.

What was the significance of the Street v New York case? ›

In Street v. New York, 394 U.S. 576 (1969), the Court issued its ruling by citing the First Amendment's protection of “words” but side-stepped the controversial “action” of flag-burning. The Court overturned the appellant's conviction under a New York statute that made it illegal to desecrate the American flag.

What was the significance of the United States v Leon case? ›

In the Supreme Court case, United States v. Leon, the Supreme Court ruled that evidence could be admitted at trial in some circ*mstances, even when it does not abide by the exclusionary rule of the Fourth Amendment. The Fourth Amendment holds that every citizen is protected from unwarranted search and seizure.

What is the significance of the United States v Windsor case? ›

In a landmark decision issued on June 27, 2013, the Supreme Court ruled that Section 3 of DOMA is unconstitutional and that the federal government cannot discriminate against married lesbian and gay couples for the purposes of determining federal benefits and protections.

Top Articles
Latest Posts
Article information

Author: Tyson Zemlak

Last Updated:

Views: 6460

Rating: 4.2 / 5 (63 voted)

Reviews: 94% of readers found this page helpful

Author information

Name: Tyson Zemlak

Birthday: 1992-03-17

Address: Apt. 662 96191 Quigley Dam, Kubview, MA 42013

Phone: +441678032891

Job: Community-Services Orchestrator

Hobby: Coffee roasting, Calligraphy, Metalworking, Fashion, Vehicle restoration, Shopping, Photography

Introduction: My name is Tyson Zemlak, I am a excited, light, sparkling, super, open, fair, magnificent person who loves writing and wants to share my knowledge and understanding with you.