The meaning of the commerce clause was at issue in the 1824 Gibbons vs. Ogden case. Aaron Ogden had been given exclusive license by the state of New York to operate steam-powered ferryboats between New York and New Jersey. Thomas Gibbons obtained a license from the U.S. government to operate boats in the same area, and when he decided to compete with Ogden, Ogden sued, and the case went to the Supreme Court. Several issues were at stake in defining federalism:
• The definition of commerce - When New York's highest court ruled against Gibbons, defined commerce narrowly as only the shipment of goods, not navigation or the transport of people.
• National governments powers over intrastate commerce-Does the national government have the right to control any commerce within a state's boundaries?
• State government's powers over interstate commerce-Is interstate commerce a concurrent power that states may share with the national government?
John Marshall wrote the majority opinion in the case, an expansive interpretation of the commerce clause that increased the national government's authority over all areas of economic affairs. Marshall defined commerce as all business dealings, not just the transfer of goods, and he ruled that the national government could regulate within states' jurisdiction. On the other hand, interstate commerce is solely the right of the national government, and so the New York court had no right to prohibit Gibbons trade.
Heart of Atlanta Motel Inc. v. United States, 379 U.S. 241 (1964), was a landmark United States Supreme Court case holding that the U.S. Congress could use the Constitution's Commerce Clause power to force private businesses to abide by the Civil Rights Act of 1964.This important case represented an immediate challenge to the Civil Rights Act of 1964, the landmark piece of civil rights legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875. For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation, a system of racial separation which, while in name providing for "separate but equal" treatment of both white and black Americans, in truth perpetuated inferior accommodation, services, and treatment for black Americans.The Heart of Atlanta motel was a large, 216-room motel in Atlanta, Georgia, which refused to rent rooms to black patrons, in direct violation of the terms of the act. The owner of the motel, Moreton Rolleston, filed suit in federal court, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. In addition, the owner argued that the act violated his Fifth Amendment rights to choose customers and operate his business as he wished and resulted in unjust deprivation of his property without due process of law and just compensation. Finally, the owner argued that Congress had placed him in a position of involuntary servitude by forcing him to rent available rooms to blacks, thereby violating his Thirteenth Amendment rights.Announced on December 14, 1964, the opinion of the court was delivered by Justice Tom C. Clark, with concurring opinions by Justice Arthur Goldberg, Justice Hugo Black, and Justice William O. Douglas.
The Court held that Congress acted well within its jurisdiction of the Interstate Commerce clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question. While it might have been possible for Congress to pursue other methods for abolishing racial discrimination, the way in which Congress did so, according to the Court, was perfectly valid. It found no merit in the arguments pursuant to the Thirteenth Amendment, finding it hard to conceive that such an Amendment might possibly be applicable in restraining civil rights legislation. Having observed that 75% of the Heart of Atlanta Motel's clientele came from out-of-state, and that it was strategically located near Interstates 75 and 85 as well as two major U.S. Highways, the Court found that the business clearly affected interstate commerce. As such, it therefore upheld the permanent injunction issued by the District Court, and required the Heart of Atlanta Motel to receive business from clientele of all races.
South Dakota v. Dole, 483 U.S. 203 (1987), was a case in which the United States Supreme Court considered the limitations the Constitution places on the authority of the United States Congress when it uses its authority to influence the individual states in areas of authority normally reserved to the states. It upheld the constitutionality of a federal statute that withheld federal funds from states whose legal drinking age did not conform to federal policy.In 1984, the United States Congress passed the National Minimum Drinking Age Act, which withheld 5% of federal highway funding from states that did not maintain a minimum legal drinking age of 21. South Dakota, which allowed 19-year-olds to purchase beer containing up to 3.2% alcohol, challenged the law, naming Secretary of Transportation Elizabeth Dole as the defendant.The Supreme Court held, 7-2, that the statute represented a valid use of Congressional authority under the spending clause, and that the statute did not infringe upon the rights of the states. The Court established a five point rule for considering the constitutionality of expenditure cuts of this type, noting that:
The spending must promote "the general welfare";
The condition must be unambiguous;
The condition should relate "to the federal interest in particular national projects or programs";
The condition imposed on the States must not in itself be unconstitutional; and
The condition must not be coercive.
Writing for the majority, Chief Justice William Rehnquist noted that the National Minimum Drinking Age Act clearly met the first three restrictions, leaving only the latter two restrictions worthy of consideration. Rehnquist wrote that the Congress did not violate the Tenth Amendment because it merely exercised its right to control its spending. Rehnquist wrote that the Congress did not coerce the states because it only cut a small percentage of federal funding, thus applying pressure, but not irresistible pressure.
United States v. Alfonso Lopez, Jr., 514 U.S. 549 (1995) was the first United States Supreme Court case since the New Deal to set limits to Congress's power under the Commerce Clause of the United States Constitution.Alfonso Lopez, Jr. was a 12th grade student at Edison High School in San Antonio, Texas. On March 10, 1992 he carried a concealed .38 caliber revolver, along with five cartridges, into the school. The gun was not loaded; Lopez claimed that he was to deliver the weapon to another person, a service for which he would receive $40. He was confronted by school authorities — the school had received anonymous tips that Lopez was carrying the weapon — and admitted to having the weapon. The next day, he was charged with violation of the federal. Gun-Free School Zones Act of 1990 (the "Act"), 18 U.S.C. § 922(q).
Lopez moved to dismiss the indictment on the ground that §922(q) of the Act was "unconstitutional as it is beyond the power of Congress to legislate control over our public schools." The trial court denied the motion, ruling that §922(q) was "a constitutional exercise of Congress' well defined power to regulate activities in and affecting commerce, and the 'business' of elementary, middle and high schools... affects interstate commerce."In a 5-4 decision, the Supreme Court affirmed the decision of the Court of Appeals. It held that while Congress had broad lawmaking authority under the Commerce Clause, the power was limited, and did not extend so far from "commerce" as to authorize the regulation of the carrying of handguns, especially when there was no evidence that carrying them affected the economy on a massive scale.
Chief Justice Rehnquist, delivering the opinion of the Court, identified the three broad categories of activity that Congress could regulate under the Commerce Clause:
the channels of interstate commerce,
the instrumentalities of interstate commerce, or persons or things in interstate commerce, and
activities that substantially affect or substantially relate to interstate commerce.
The Court summarily dismissed any consideration of the first two categories and concluded that the resolution of the case depended only on consideration of the third category—regulation of activities that substantially affect interstate commerce. The Court essentially concluded that in no way was the carrying of handguns a commercial activity or even related to any sort of economic enterprise, even under the most extravagant definitions.
Gonzales v. Raich (previously Ashcroft v. Raich), 545 U.S. 1 (2005), was a decision by the United States Supreme Court ruling that under the Commerce Clause of the United States Constitution, the United States Congress may criminalize the production and use of home-grown cannabis (weed) even where states approve its use for medicinal purposes.California voters passed Proposition 215 in 1996, legalizing the medical use of marijuana. The United States Federal Government has limited the use of marijuana since the 1937 Marijuana Tax Act came into effect. Defendant Angel Raich used homegrown medical marijuana, which was legal under California law, but illegal under federal law. On August 15, 2002, Butte County Sheriff's Department officers and agents from the federal Drug Enforcement Administration (DEA) destroyed all six of California resident Diane Monson's marijuana plants, facing light resistance. The marijuana plants were illegal Schedule I drugs under the federal Controlled Substances Act (CSA). CSA is Title II of the Comprehensive Drug Abuse Prevention and Control Act of 1970. Monson and Angel Raich sued, claiming that enforcing the CSA against them would violate the Commerce Clause, the Due Process Clause of the Fifth Amendment to the United States Constitution, the Ninth Amendment to the United States Constitution, the Tenth Amendment to the United States Constitution, and the doctrine of medical necessity.
Angel Raich's physician has stated that, without marijuana, Angel's life is threatened by excruciating pain. California was one of fourteen states (now twenty) that allowed medicinal use of marijuana. California's Compassionate Use Act allows limited use of marijuana for medicinal purposes.The starting point for the Court's opinion was the fact that it was conceded that Congress had the power to control or ban marijuana for non-medical uses:
Respondents in this case do not dispute that passage of the CSA, as part of the Comprehensive Drug Abuse Prevention and Control Act, was well within Congress' commerce power. Nor do they contend that any provision or section of the CSA amounts to an unconstitutional exercise of congressional authority. Rather, respondents' challenge is actually quite limited; they argue that the CSA's categorical prohibition of the manufacture and possession of marijuana as applied to the intrastate manufacture and possession of marijuana for medical purposes pursuant to California law exceeds Congress' authority under the Commerce Clause.
Banning the growing of marijuana for medical use, the Court reasoned, was a permissible way of preventing or limiting access to marijuana for other uses:
Even respondents acknowledge the existence of an illicit market in marijuana; indeed, Raich has personally participated in that market, and Monson expresses a willingness to do so in the future. More concretely, one concern prompting inclusion of wheat grown for home consumption in the 1938 Act was that rising market prices could draw such wheat into the interstate market, resulting in lower market prices. Wickard, 317 U.S., at 128. The parallel concern making it appropriate to include marijuana grown for home consumption in the CSA is the likelihood that the high demand in the interstate market will draw such marijuana into that market. While the diversion of homegrown wheat tended to frustrate the federal interest in stabilizing prices by regulating the volume of commercial transactions in the interstate market, the diversion of homegrown marijuana tends to frustrate the federal interest in eliminating commercial transactions in the interstate market in their entirety. In both cases, the regulation is squarely within Congress' commerce power because production of the commodity meant for home consumption, be it wheat or marijuana, has a substantial effect on supply and demand in the national market for that commodity.
Plessy v. Ferguson (1896), is a landmark United States Supreme Court decision in the jurisprudence of the United States, upholding the constitutionality of state laws requiring racial segregation in public facilities under the doctrine of "separate but equal".
The decision was handed down by a vote of 7 to 1 with the majority opinion written by Justice Henry Billings Brown and the dissent written by Justice John Marshall Harlan. "Separate but equal" remained standard doctrine in U.S. law until its repudiation in the 1954 Supreme Court decision Brown v. Board of Education.
After the Supreme Court ruling, the New Orleans Comité des Citoyens (Committee of Citizens), which had brought the suit and arranged for Homer Plessy's arrest in order to challenge Louisiana's segregation law, replied, "We, as freemen, still believe that we were right and our cause is sacred.In a 7 to 1 decision handed down on May 18, 1896 (Justice David Josiah Brewer did not participate because of the death of his daughter), the Court rejected Plessy's arguments based on the Fourteenth Amendment, seeing no way in which the Louisiana statute violated it. In addition, the majority of the Court rejected the view that the Louisiana law implied any inferiority of blacks, in violation of the Fourteenth Amendment. Instead, it contended that the law separated the two races as a matter of public policy.
When summarizing, Justice Brown declared, "We consider the underlying fallacy of the plaintiff's argument to consist in the assumption that the enforced separation of the two races stamps the colored race with a badge of inferiority. If this be so, it is not by reason of anything found in the act, but solely because the colored race chooses to put that construction upon it."
Death w/ Dignity Act, legalized physician assisted suicide, under the conditions that the person has to do it the doctor can only give them the lethal drugs, agreed by two doctors to be within six months of dying from an incurable condition.On November 9, 2001, Attorney General John Ashcroft issued an Interpretive Rule that physician-assisted suicide was not a legitimate medical purpose, and that any physician administering federally controlled drugs for that purpose would be in violation of the Controlled Substances Act. The State of Oregon, joined by a physician, a pharmacist, and a group of terminally ill patients, all from Oregon, filed a challenge to the Attorney General's rule in the U.S. District Court for the District of Oregon. The court ruled for Oregon and issued a permanent injunction against the enforcement of the Interpretive Rule. The ruling was affirmed by the Ninth Circuit Court of Appeals.In a 6-3 decision written by Justice Anthony Kennedy, the Court affirmed the Ninth Circuit's judgment, but employed different reasoning. The majority opinion did not dispute the power of the federal government to regulate drugs, but disagreed that the statute in place empowered the U.S. Attorney General to overrule state laws determining what constituted the appropriate use of medications that were not themselves prohibited. The court found that it was inappropriate to apply Chevron deference toward the Attorney General's "interpretive rule" that controlled substances could not medically be used for the purpose of physician-assisted suicide. Dred Scott v. Sandford, 60 U.S. 393 (1857), was a landmark decision by the U.S. Supreme Court in which the Court held that African Americans, whether slave or free, could not be American citizens and therefore had no standing to sue in federal court, and that the federal government had no power to regulate slavery in the federal territories acquired after the creation of the United States. Dred Scott, an African American slave who had been taken by his owners to free states and territories, attempted to sue for his freedom. In a 7-2 decision written by Chief Justice Roger B. Taney, the Court denied Scott's request and in doing so, ruled an Act of Congress to be unconstitutional for the second time in its history.
Although Taney hoped that his ruling would settle the slavery question once and for all, the decision immediately spurred wide public debate. Most scholars and many contemporary political figures (including the leadership of the then-new Republican Party) considered that the ruling regarding slavery in the territories to not be binding precedent, but instead mere dictum. The decision would prove to be an indirect catalyst for the American Civil War and was functionally superseded by the post-war Reconstruction Amendments. It is now widely regarded as the worst decision ever made by the Supreme Court.