Tuesday, September 11, 2012

United States v. Morrison, 529 U.S. 598, 120 S. Ct. 1740, 146 L. Ed. 2d 658 (2000)



Facts
Former university student brought claims under Violence Against Women Act (VAWA) against students who allegedly raped her.
The U.S. District Court dismissed claims.
Former student appealed. 
Following reversal and following rehearing en banc, the Fourth Circuit affirmed.
Certiorari was granted. 

Holding
The Supreme Court held that:

  1. Commerce Clause did not provide Congress with authority to enact civil remedy provision of VAWA, inasmuch as provision was not regulation of activity that substantially affected interstate commerce, and  
  2. enforcement clause of Fourteenth Amendment did not provide Congress with authority to enact provision.

Affirmed.