In upholding the Driver's Privacy Protection Act, the Supreme Court granted Congress the constitutional authority under the Commerce Clause to override state FOI laws in order to restrict disclosure of drivers' license data. The Court treated states as database owners and public records as commodities in interstate commerce. In doing so, this research contends, the Court has opened the door for Congress to limit access to a myriad of other state and local public records containing personal, but not necessarily private, information. This paper argues that the Court should have adopted the reasoning of those lower courts that struck down the statute as a federal infringement upon states' rights. Under an alternate approach to deciding the case, the Court could have avoided the muddy waters of Tenth Amendment jurisprudence and issued a limited decision, treating drivers' license data as a special category outside the purview of Congress.