## Facts

- Congress enacted the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), replacing AFDC with the TANF block-grant program and amending the federal Child Support Enforcement (Title IV-D) program.
- Title III of PRWORA required participating states to implement child-support enforcement measures, including a statewide case registry of child support orders and a state directory of new hires to be matched against state and federal databases and a national directory.
- Kansas participated in TANF and IV-D and sought declaratory and injunctive relief, contending the new IV-D data-system and reporting requirements were costly, intrusive, and administratively burdensome.
- Kansas argued the conditions effectively forced compliance because noncompliance risked loss of substantial TANF and IV-D funds, leaving the state with no meaningful choice.
- The district court dismissed the complaint for failure to state a claim, and Kansas appealed.

## Issues

1. Whether Title III’s conditions on federal TANF and IV-D funds exceed Congress’s Spending Clause authority because the conditions are insufficiently related to the federal interest and are unconstitutionally coercive.
2. Whether Title III’s requirements violate the Tenth Amendment by commandeering state legislative or executive functions.

## Decision

- The court of appeals affirmed dismissal for failure to state a claim.
- The court held Title III is a valid exercise of Congress’s Spending Clause power.
- The court rejected the claim that the conditions were unrelated to the federal interest, concluding the requirements further the objectives of TANF and child-support enforcement by improving collection and reducing welfare dependency.
- The court rejected the coercion argument, holding that offering funds conditioned on compliance did not amount to unconstitutional compulsion.
- The court held the requirements did not constitute commandeering because Kansas could decline participation in the federal funding programs.

## Legal Principles

- Congress may condition federal funds to states if the conditions serve the general welfare, are unambiguous, relate to the federal interest in the funded program, do not require unconstitutional action, and do not become so coercive that pressure becomes compulsion.
- Relatedness is satisfied when conditions reasonably advance the federal objectives of the funded program, including measures aimed at increasing administrative effectiveness and uniformity.
- A conditional spending program generally does not violate the Tenth Amendment anti-commandeering rule when states retain the formal option to accept or decline the funds.
- Lower federal courts must apply controlling Supreme Court Spending Clause precedent and may not narrow or overrule it.

## Conclusion

The court upheld PRWORA Title III’s child-support enforcement conditions, concluding that the requirements were sufficiently connected to federal welfare and support-collection goals, did not cross the constitutional line into coercion, and did not commandeer state government because participation remained voluntary.


Kansas v. United States, 214 F.3d 1196 (10th Cir. 2000)