...attempted to prevent the use of their states' NG forces for Reagan's adventures in Central America.
Congress closed the loophole in an amendment to the '87 DoD budget. Courts threw out their challenge to the amendment.
In Perpich v. Department of Defense, <21> a unanimous Supreme Court ruled that Congress can "authorize the President to order members of the National Guard to active duty for purposes of training outside the United States during peace time without either the consent of a state governor or the declaration of a national emergency."<22> At issue was the constitutionality of a statute <23> that prohibits state and territorial governors (including the authorities in Puerto Rico and the District of Columbia) from withholding their consent to the federal activation of National Guard units, when the governors' withholding is premised on objections to the "location, purpose, type, or schedule" of the duty. Governor Rudy Perpich of Minnesota had argued that this statute conflicted with the express reservation to the states in the Militia Clause of the "Authority of training the Militia according to the discipline prescribed by Congress."LinkMy guess is that there's even less chance such a challenge would work today, given we do have a declared national emergency.