Gonzales v. Raich
Citation: 545 U.S. 1 (2005)
Facts
California’s Compassionate Use Act permitted seriously ill residents to grow and use marijuana for medical purposes with a doctor’s recommendation. Angel Raich and Diane Monson grew marijuana at home for personal medical use, as authorized by state law. Federal agents destroyed their plants pursuant to the Controlled Substances Act. Raich challenged the CSA as applied to intrastate, noncommercial marijuana cultivation and use.
Issue
Does Congress have authority under the Commerce Clause to prohibit the local cultivation and use of marijuana that is never sold or transported in interstate commerce?
Holding
Yes. The Supreme Court upheld federal authority, finding that Congress could rationally conclude that homegrown marijuana, taken in the aggregate, substantially affects interstate commerce in marijuana and therefore falls within the commerce power.
Rule
Under the substantial effects test, Congress may regulate purely local, noncommercial activity if it is part of a larger class of activities that, in the aggregate, substantially affect interstate commerce. When regulating a broader economic market, Congress may regulate even those individual instances that do not themselves have substantial effects.
Significance
Raich is the Court’s most recent significant affirmation of broad Commerce Clause power, reaffirming Wickard v. Filburn after the Lopez and Morrison decisions narrowed it. It is essential for understanding the outer limits of federal criminal jurisdiction under the Commerce Clause.