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Keywords

statutetrialcomplianceself-incrimination
jurisdictiontrialcomplianceappellee

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Selective Service System v. Minnesota Public Interest Research Group, 468 U.S. 841, 104 S.Ct. 3348, 82 L.Ed.2d 632, 18 Ed. Law Rep. 115

Facts

The case arose when several anonymous male students, who had failed to register for the draft as required by the Military Selective Service Act, sought to enjoin the enforcement of Section 12(f) of the Act. This section denied federal financial assistance under Title IV of the Higher Education Act of 1965 to those who did not register. The District Court initially ruled in favor of the students, asserting that the statute was unconstitutional as it imposed penalties on nonregistrants without a judicial trial and violated their Fifth Amendment rights against self-incrimination.

Section § 12(f) to the Military Selective Service Act denies federal financial assistance under Title IV of the Higher Education Act of 1965 to male students between the ages of 18 and 26 who fail to register for the draft.

Issue

The main legal issues were whether Section 12(f) of the Military Selective Service Act constituted a bill of attainder and whether it compelled students to incriminate themselves in violation of the Fifth Amendment.

We noted probable jurisdiction to decide (a) whether § 12(f) of the Military Selective Service Act… is a bill of attainder; and (b) whether § 12(f) compels those students who elect to request federal aid to incriminate themselves in violation of the Fifth Amendment.

Rule

A bill of attainder is defined as a law that legislatively determines guilt and inflicts punishment upon an identifiable individual without provision of the protections of a judicial trial. Additionally, the Fifth Amendment protects individuals from being compelled to incriminate themselves.

A bill of attainder is “a law that legislatively determines guilt and inflicts punishment upon an identifiable individual without provision of the protections of a judicial trial.”

Analysis

The Supreme Court analyzed Section 12(f) and determined that it did not single out nonregistrants for punishment based on past conduct, as it allowed for late registration and did not impose irreversible penalties. The Court found that the statute's purpose was to encourage compliance with the draft registration requirement rather than to punish nonregistrants. Furthermore, the Court concluded that the statute did not compel students to disclose incriminating information, as they were not required to seek financial aid and could register late without disclosing their registration status.

The legislative history shows that § 12(f) was intended to further nonpunitive legislative goals. Conditioning receipt of Title IV aid on draft registration is plainly a rational means to improve compliance with the registration requirements.

Conclusion

The Supreme Court reversed the District Court's ruling, holding that Section 12(f) was not a bill of attainder and did not violate the Fifth Amendment rights of the students.

We conclude that § 12(f) does not violate the proscription against bills of attainder. Nor have appellees raised a cognizable claim under the Fifth Amendment.

Who won?

The prevailing party was the Selective Service System, as the Supreme Court reversed the lower court's decision and upheld the constitutionality of Section 12(f). The Court reasoned that the statute did not impose punishment and allowed for compliance through late registration.

The judgment of the District Court is Reversed.

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