Congress ordered the Secretary of Transportation to withhold 5% of federal highway funds from states that failed to set a minimum drinking age of 21. South Dakota, which allowed 19-year-olds to buy 3.2% beer, sued. Chief Justice Rehnquist announced a five-factor spending-power test: the exercise must (1) promote the general welfare, (2) be unambiguous, (3) relate to the federal interest in the program funded, (4) not require states to violate other constitutional provisions, and (5) not be so coercive that it 'passes the point at which pressure turns into compulsion.' The 5% highway penalty was 'relatively mild encouragement,' not coercion. Dole is the workhorse precedent behind virtually every federal grant program with strings attached — from Title IX to Medicaid — and its coercion prong was reactivated in NFIB v. Sebelius (2012) to strike down the ACA's mandatory Medicaid expansion.