Selective Service System v. Minnesota Public Interest Research Group
Headline: Court allows conditioning federal student financial aid on draft registration, upholding a law that blocks aid for men who fail to register while allowing late registration to regain eligibility.
Holding: The Court ruled that Congress may deny Title IV student aid to men who fail to register for the draft, that the law is not an unconstitutional attainder, and that it does not compel self-incrimination as applied here.
- Men who fail to register may lose federal student aid unless they register.
- Students can generally regain eligibility by registering late and filing the compliance statement.
- Raises concerns about coercion and unequal effects on low-income students.
Summary
Background
A group of anonymous male students who had not registered for the draft sued after Congress added a rule denying federal Title IV student aid to men who failed to register. The rule required schools to collect a statement that applicants were in compliance with Selective Service. Federal regulations later allowed a student who had not registered to become eligible by registering and filing a compliance statement. A federal district court enjoined the law, finding it likely to be an unconstitutional bill of attainder and to force students to incriminate themselves; the Government appealed and the Supreme Court heard the case.
Reasoning
The Court addressed whether the law singles out past nonregistrants for punishment or forces them to confess a crime. The majority read the statute and its history to show Congress intended encouragement, not punishment, and noted regulations let late registrants regain eligibility. The Court relied on historical ideas of punishment and several tests, concluding the denial of aid is a nonpunitive, rational condition to improve compliance and allocate limited funds. The Court also held that the aid application and compliance statement do not require students to disclose incriminating facts to their schools, and that seeking aid is voluntary, so there was no Fifth Amendment violation for these plaintiffs. Justice Powell agreed that the law is nonpunitive.
Real world impact
Men who have not registered for the draft risk losing Title IV aid unless they register; they can generally cure ineligibility by registering and filing the compliance statement. The decision reversed a nationwide injunction and leaves the statutory scheme in force while noting critics’ concerns. The ruling was not unanimous; some Justices warned it may coerce low-income students and could raise Fifth Amendment or equal protection problems.
Dissents or concurrances
Justice Marshall (joined by Justice Brennan) dissented arguing the law coerces late registration and thus forces self-incrimination and disproportionately harms poorer students. Justice Powell concurred in the judgment, emphasizing the nonpunitive purpose.
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