In Dakota v. Dole, 483 U.S. 203, 208, 107 S. Ct. 2793, 97 L. Ed. 2d 171 (1987), the Court held that 23 U.S.C. 158 was constitutional, finding that conditioning receipt of federal highway funds on state enactment of minimum drinking age laws was a proper exercise of Congress' spending power. The Court noted, though, that the "spending power is of course not unlimited, but is instead subject to several general restrictions articulated in our cases." Id. at 207. In her dissent in Dole, Justice O'Connor agreed "that there are four separate types of limitations on the spending power," but argued that the majority's "application of the requirement that the condition imposed be reasonably related to the purpose for which the funds are expended is cursory and unconvincing." 483 U.S. at 213 (O'Connor, J., dissenting). When Congress appropriates money to build a highway, it is entitled to insist that the highway be a safe one. But it is not entitled to insist as a condition of the use of highway funds that the State impose or change regulations in other areas of the State's social and economic life because of an attenuated or tangential relationship to highway use or safety. Indeed, if the rule were otherwise, the Congress could effectively regulate almost any area of a State's social, political, or economic life on the theory that use of the interstate transportation system is somehow enhanced. Id. at 215 (O'Connor, J., dissenting). She argued that Congress is only authorized under the Spending Clause to " 'specify how the money should be spent.' " Id. at 216 (O'Connor, J., dissenting) (quoting Br. for Nat'l Conf. Amici Curiae). " 'A requirement that is not such a specification is not a condition, but a regulation, which is valid only if it falls within one of Congress' delegated regulatory powers.' " Id. Indeed, she warns, if the spending power is to be limited only by Congress' notion of the general welfare, the reality, given the vast financial resources of the Federal Government, is that the Spending Clause gives "power to the Congress to tear down the barriers, to invade the states' jurisdiction, and to become a parliament of the whole people, subject to no restrictions save such as are self-imposed." United States v. Butler 297 U.S. at 78. This, of course, as Butler held, was not the Framers' plan and it is not the meaning of the Spending Clause. Id. at 217 (O'Connor, J., dissenting).