The case of New York v. United States (1991) revolved around the constitutionality of three provisions in the Low-Level Radioactive Waste Policy Amendments Act of 1985, which required states to provide for disposal of low-level radioactive waste generated within their borders. The Supreme Court held that while Congress could incentivize states to regulate according to federal standards by offering monetary incentives or access to beneficial programs, it could not compel them directly under threat of penalty - a principle known as "cooperative federalism". Two out of three challenged provisions were upheld; one providing monetary incentives and another granting access rights at disposal sites. However, the third provision was struck down because it forced state governments into owning and taking responsibility for waste if they did not comply with regulatory statutes – essentially coercing them into regulating in accordance with federal law. This decision reinforced principles limiting Congressional power over state governments under the Tenth Amendment.

In the dissenting opinion for New York v. United States, Justice White argued that Congress had the authority to regulate radioactive waste under the Commerce Clause and could therefore require states to take responsibility for their own waste. He contended that this did not violate principles of federalism because it was a necessary measure in response to a national problem. Furthermore, he disagreed with the majority's interpretation of "coercion," arguing that financial incentives or penalties used by Congress do not constitute coercion but are rather legitimate tools of governance. He also pointed out inconsistencies in how these principles were applied across different cases and warned against an overly rigid approach to federalism which might hinder effective government action on important issues.