Printz v. United States
Citation
521 U.S. 898 (1997)
Facts
The Brady Handgun Violence Prevention Act required chief law enforcement officers (CLEOs) of local jurisdictions to perform background checks on prospective gun purchasers in the interim period before a national background-check system was operational. Jay Printz, a Montana county sheriff, refused to comply and challenged the provision as unconstitutional commandeering of state executive officers.
Issue
May Congress compel state executive officers to administer and enforce a federal regulatory program?
Holding
No. The Supreme Court held, 5–4, that the Brady Act’s interim provision commandeering state CLEOs was unconstitutional. The federal government cannot direct state officers to administer a federal program.
Rule / Doctrine
Anti-commandeering doctrine (executive): extending New York v. United States from legislative to executive commandeering. The Constitution’s structure — dual sovereignty, separation of powers, and the President’s duty to “take Care that the Laws be faithfully executed” — prohibits Congress from conscripting state executive officers into federal service. The federal government must use its own executive apparatus to enforce federal law.
Significance
Printz completes the anti-commandeering doctrine alongside New York v. United States. It is notable for Justice Scalia’s historical and structural analysis, and for rejecting Garcia’s suggestion that political safeguards of federalism suffice. Justice O’Connor’s concurrence preserved a role for voluntary state cooperation. Anti-commandeering has become central to debates over federal marijuana law, immigration enforcement, and gun regulations.