The United States (defendant) passed a law providing appropriations of tax funds to the states for the purpose of implementing programs to reduce infant mortality. The law required states accepting funds to report on their compliance with program requirements and authorized the withholding of funds to any state found not to be in compliance. The state of Massachusetts (plaintiff) filed suit claiming that the law presented an unconstitutional infringement upon the sovereignty of the states. The United States Supreme Court consolidated Massachusetts’ case with the case of Frothingham. Frothingham was an individual taxpayer who filed suit claiming that the law violated the Constitution by implementing a governmental taking of property, in the form of taxation, without due process of law.